May 12, 2015

Exemption No. 11552

Regulatory Docket No. FAA–2015–0374

Mr. Jeffrey A. Miller

Assistant Vice President, Workforce Development

Sinclair Community College

444 West Third Street

Dayton, OH 45402

Dear Mr. Miller:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

The Basis for Our Decision

By letter dated February 12, 2015, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Sinclair Community College (hereinafter petitioner or operator) for an 

exemption. The petitioner requested to operate an unmanned aircraft system (UAS) to 

conduct educational research and training.

See Appendix A for the petition submitted to the FAA describing the proposed operations and 

the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitioner is an Altavian Nova F6500.
2

The petitioner requested relief from 14 CFR part 21, Certification procedures for products 

and parts, Subpart H—Airworthiness Certificates. 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 Secretary of Transportation has determined that this aircraft 

meets the conditions of Section 333. Therefore, the FAA finds that the requested relief from 

14 CFR part 21 and any associated noise certification and testing requirements of part 36, is 

not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial data collection. The FAA has issued grants of 

exemption in circumstances similar in all material respects to those presented in your petition. 

In Grants of Exemption Nos. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 

11109 to Clayco, Inc. (see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC (see

Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. 

FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned 

aircraft (UA) with the specifications described by the petitioner and carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions, carrying crew in 

addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled 

by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in Grant of 

Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 

11213 also apply to the situation you present; and 

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. 

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, 

delegated to me by the Administrator, Sinclair Community College is granted an exemption 

from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 

91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) 

and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data 

collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Sinclair Community College is hereafter referred to as 

the operator.
3

Failure to comply with any of the conditions and limitations of this grant of exemption will be 

grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exemption are limited to the Altavian Nova 

F6500 when weighing less than 55 pounds including payload. Proposed operations of 

any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are 

not permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine 

compliance with the 87 knot speed restriction. In no case will the UA be operated at 

airspeeds greater than the maximum UA operating airspeed recommended by the 

aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level 

(AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. 

This requires the PIC to be able to use human vision unaided by any device other than 

corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or

U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within 

the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used 

to satisfy the VLOS requirement as long as the PIC always maintains VLOS 

capability. The VO and PIC must be able to communicate verbally at all times;

electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the 

duration of the flight. The PIC must ensure that the VO can perform the duties 

required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its 

operations in accordance with the conditions and limitations stated in this grant of 

exemption, are hereinafter referred to as the operating documents. The operating 

documents must be accessible during UAS operations and made available to the 

Administrator upon request. If a discrepancy exists between the conditions and 

limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. 

Otherwise, the operator must follow the procedures as outlined in its operating 

documents. The operator may update or revise its operating documents. It is the 

operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator or any law enforcement official upon request. The 
4

operator must also present updated and revised documents if it petitions for extension 

or amendment to this grant of exemption. If the operator determines that any update 

or revision would affect the basis upon which the FAA granted this exemption, then 

the operator must petition for an amendment to its grant of exemption. The FAA’s 

UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g., replacement of a flight critical component, must undergo 

a functional test flight prior to conducting further operations under this exemption. 

Functional test flights may only be conducted by a PIC with a VO and must remain at 

least 500 feet from other people. The functional test flight must be conducted in such 

a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is

in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the 

UAS is in a condition for safe flight. The pre-flight inspection must account for all 

potential discrepancies, e.g., inoperable components, items, or equipment. If the 

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is 

prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, 

replacement, inspection, and life limit requirements for the aircraft and 

aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer 

safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, 

commercial, private, recreational, or sport pilot certificate. The PIC must also hold a 

current FAA airman medical certificate or a valid U.S. driver’s license issued by a 

state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal 

government. The PIC must also meet the flight review requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the 

ability to safely operate the UAS in a manner consistent with how the UAS will be 

operated under this exemption, including evasive and emergency maneuvers and 

maintaining appropriate distances from persons, vessels, vehicles and structures. PIC 

qualification flight hours and currency must be logged in a manner consistent with 

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 
5

(training, proficiency, and experience-building) and determining the PIC’s ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated 

under this exemption are permitted under the terms of this exemption. However, 

training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for 

flight operations are considered nonparticipants, and the PIC must operate the UA 

with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights 

under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not 

denoted with an ARP, the center of the airport symbol as denoted on the current 

FAA-published aeronautical chart, unless a letter of agreement with that airport’s 

management is obtained or otherwise permitted by a COA issued to the exemption 

holder. The letter of agreement with the airport management must be made available 

to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet 

horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location within the private or controlled-access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the UA to conduct the 

intended operation and to operate after that for at least five minutes or with the reserve 

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All 

operations shall be conducted in accordance with an ATO-issued COA. The 

exemption holder may apply for a new or amended COA if it intends to conduct 

operations that cannot be conducted under the terms of the attached COA.

22. All aircraft operated in accordance with this exemption must be identified by serial 

number, registered in accordance with 14 CFR part 47, and have identification 

(N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable.
6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and 

any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Administrator or any law enforcement 

official upon request.

24. The UA must remain clear and give way to all manned aviation operations and 

activities at all times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating 

persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure 

that nonparticipating persons remain under such protection. If a situation arises 

where nonparticipating persons leave such protection and are within 500 feet of 

the UA, flight operations must cease immediately in a manner ensuring the safety 

of nonparticipating persons; and

b. The owner/controller of any vessels, vehicles or structures has granted permission 

for operating closer to those objects and the PIC has made a safety assessment of 

the risk of operating closer to those objects and determined that it does not 

present an undue hazard.

The PIC, VO, operator trainees or essential persons are not considered 

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled-access property with 

permission from the property owner/controller or authorized representative. 

Permission from property owner/controller or authorized representative will be 

obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defined by the applicable COA must be reported 

to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be 

reported to the National Transportation Safety Board (NTSB) per instructions 

contained on the NTSB Web site: www.ntsb.gov.

If this exemption permits operations for the purpose of closed-set motion picture and 

television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) 

as documented in this grant of exemption.
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30. At least 3 days before aerial filming, the operator of the UAS affected by this 

exemption must submit a written Plan of Activities to the local Flight Standards 

District Office (FSDO) with jurisdiction over the area of proposed filming. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following:

a. Dates and times for all flights;

b. Name and phone number of the operator for the UAS aerial filming conducted 

under this grant of exemption;

c. Name and phone number of the person responsible for the on-scene operation of 

the UAS;

d. Make, model, and serial or N−Number of UAS to be used;

e. Name and certificate number of UAS PICs involved in the aerial filming;

f. A statement that the operator has obtained permission from property owners 

and/or local officials to conduct the filming production event; the list of those 

who gave permission must be made available to the inspector upon request;

g. Signature of exemption holder or representative; and

h. A description of the flight activity, including maps or diagrams of any area, city, 

town, county, and/or state over which filming will be conducted and the altitudes 

essential to accomplish the operation.

31. Flight operations may be conducted closer than 500 feet from participating persons 

consenting to be involved and necessary for the filming production, as specified in the 

exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS 

operations must comply with all applicable parts of 14 CFR including, but not limited to, 

parts 45, 47, 61, and 91.

This exemption terminates on May 31, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service
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TABLE OF CONTENTS 

Page 

GLOSSARY OF ABBREVIATIONS ...............................................................................................3 

SUMMARY......................................................................................................................................4 

INTRODUCTION AND INTERESTS OF THE PETITIONER ......................................................4 

BACKGROUND ...............................................................................................................................5 

BASISFOR PETITION ....................................................................................................................6 

A. Name And Address Of The Petitioner .......................................................................................7 

B. The Specific Sections Of 14 CFR From Wliich Sinclair Seeks Exemption ..............................7 

C. The Extent Of Relief Sinclair Seeks And The Reason Sinclair Seeks The Relief . ...................9 

D. Tlhe Reasons Wliy Granting Sinclair's Rcquest Wotrld Be ln The Public Interest ..................10 

E. The Reasons Wlty Granting The Exemption Would Not Adversely Affect Safety ................12 

F. A Suinmary That Can Be Published In The Federal Regislei . ................................................24 

G. Any Additional Information, Views, Or Argurnents Available To Support Sinclair's 

Request . ...........................................................................................................................................2 5 

CONCLUSION...............................................................................................................................26 

Attachmerit 1 MOA between Clinton County Port Authority and Sinclair Cotnmunity College ..... 27 

Attachment 2 COA for Wilmington Air Park ..................................................................................36 

Attachrnent 3 Nova F6500 Operator Manual ...................................................................................61 

Attachment 4 Nova F6500 Maintenance Manual ..........................................................................149 

2 
GLOSSARY OF ABBREVIATIONS 

AGL above ground level 

ATC air traffic control 

AV aerial vehicle 

COA Certificate of Authorization 

CFR Code of I'ederal Regulations 

EPA Environmental Protection Agency 

FAA Federal Aviation Administration 

FAR Federal Aviation Regulation 

FCC Federal Conununications Commission 

FMRA FAA Modernization and Reform Act of 2012 (P.L. 1] 2-95) 

GCS ground control station 

K[LN Wilmington Air Park 

MOA Memorandum of Agreement 

MSL mean sea level 

NAS National Airspace System 

mm nautical mile(s) 

OAT outside air temperature 

PIC Pilot In Command 

P.L. 112-95 Public Law 112-95 

Section 333 FMRA Section 333 

UA unmanned aircraft 

UAS unmanned aircraft system 

VFR visual flight i-tiles 

VI.OS visual line of sight 

VMC visual meteorological conditions 

VO visual observer 

3 
SUMMARY 

SINCLAIR COMMUNITY COLLEGE seeks exemption from the requireinents of 

Part 21 and Sections 45.23(b), 91.9(b), 91.151(a)(1), 91.203(a) &(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) &(a)(2), 91.417(a) &(b), 45.23(b), and 21.185 of Title 14 CFR to operate an 

unmanned aircra$ system (UAS) in accordance with Section 333 of the FAA Modernization 

and Reform Act of 2012. This exemption will permit SINCi..AIR COMMUNITY COLLEGE 

to operate a UAS for the purpose of educational research and training. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

SINCLAIR COMMUNITY COLLEGE (liereinafter refeffed to as "Sinclair") is a 

public conununity eollege located in Dayton, Ohio. Sinclair's mission is offer transfer and 

technical associatc degree programs, certiftcate prograrns, and continuing education 

oppoilunities through a system of diverse resources and delivery alternatives accessible to the 

citizens of Montgomery County and the larger learning community. Sinclair also prepares 

today's workforce to meet the needs of a rapidly changing, technologically advanced, global 

economy through traditional and nontraditional alternatives. Within Sinclair's structure is the 

Workforce Development Division. 

Sinclair's Workforce Development Division, UAS Branch is focused on providing 

practical, real-world applications of UAS technologies through classroom instruction, cuttingedge simulation training and hands-on vehicle operations. To that end, Sinclair intends to use 

unmanned aircraft (UA) for educational research, training, and data collection oit UAS 

operational coneepts and safety. 

Sinclair seeks to operate its Altavian Nova F6500 UAS over the Wiltnington Air Park, 

Clinton County, Ohio (KILN) Class D airspace during published air traffic control (A'I'C) tower 

operating hours. KILN Class D airspace is surrounded by Class G airspace and is located 10 nm 

from Class C airspace. KILN is located in a mostly unpopulated, agricultural area, away from 

dense population centers. The primary UAS flight area will remain over agricultural land owned 

by KILN. Specifically, the Nova F6500 UAS will be used as an educational research platform, 

to provide UAS training services to military and non-military candidates, develop business 

concepts for the use of UAS in the civilian sector, and provide the FAA with data for 

futrthering safe UAS operations in the NAS. 

4 
BACKGROUND 

Unmanned Aircraft Svstem: Altavian Nova F6500 t1AS 

Sinclair seeks an exemption to operate the Altavian Nova F6500 UAS (also known as 

the Nova Block III UAS), Serial Niunbers 3009 and 3010, for compensation or hire witliin the 

National Aii-space System (NAS). The Nova F6500 UAS is comprised of a UA and a 

transportable ground control station (GCS). The Nova F6500 UA has a maximum gross 

weight of approximately fifteen (15) pounds, a wingspan of 108 inches, and a length of 65 

inches. It is equipped with a single propeller driven by a Lithium Polymer battery powered 

electric motor. 

0 

Figure 1: The Nova F6500 UA. 

Proven Operational History at Sinclair of the Nova F6500 UAS in the NAS 

The Nova F6500 UAS is currently operating safely within the NAS under 

approximately fifteen (15) Ceirtificates of Authorization (COAs) granted by the Federal 

Aviation Administratioit (FAA) to Middle Teruiessee State University; SINCLAIR 

COMMUNITY COLLF,GE in Dayton, Ohio; the U.S. Army Corps of Engineers 

(Jacksonville District and Mobile District); Mississippi State tJniversity for the Pearl River 

Basin; University of Florida. In addition, the operator Woolpert, Inc. was granted Section 
333 waivers in December 2014 for certain operations of their Nova F6500 tJAS (Exemption 

Nos. i 1111 and 11114.) Also, the U.S. Army Corps of Engineers will be operating the Nova 

F6500 UAS pursuant to additional COAs in the foreseeable future, pending approval by the 

FAA. 

The Nova F6500 UAS is safely operating by Sinclair within the NAS under two FAA 

Certificates of Authorization (COAs) granted to Sinclair. The COA covering operations at 

KILN (2013-CSA-58) is in effect through July 25, 2015. Under this and another COA at 

Springfield Airpark, Sinclair is conducting safe and effective operations with the Nova 

F6500 UAS, completing over 44 flight hours in 128 nights. 

BASIS FOR PETITION 

Petitioner, SINCLAIR COMMUNITY COLLEGE, by and tlu•ougll undersigned 

counsel, in accordance with the provisions of the Federal Aviation Regulations (14 CFR 

Section 11.61) and the FAA Modernization and Refoim Act of 2012, Section 333, Special 

Rules for Certain Unnaanned Aircraft Systems, hereby petitions the Administrator to operate 

the Nova F6500 UAS in the NAS, and for an exemption froni the rcquirements of 14 CFR 

Part 21 and Sections 45.23(b), 91.9(b), 91.151(a)(1), 91.203(a) &(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), 91.417(a) & (b). 

In consideration of the Nova F6500 UA size, weight, speed, and limited operating 

area, Sinclair's operation of the Altavian Nova F6500 UAS does not require an airworthiness 

certificate in aecordance with 14 CFR Part 21, Subpart H. Therefore, Sinclair requests relief 

from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), 91.417(a) &(b), as these 

sections set forth requirements for aircraft wit11 an airworthiness certificate. 

Sinclair submits that the requested relief is proper since an equivalent level of safety 

will be ensured. Sinclair, as the operator of the Nova F6500 UAS, will use its trained 

technicians to perform maintenance, alterations, or preventive maintenance on the UAS using 

the methods, techniques, and practices prescribed in the manufacturer's maintenance manual. 

Furtliermore, Sinclair will document and maintain all maintenance records for the Nova F6500 

UAS. 

Sinclair also seeks an exemption from the requirements of Section 91.151(a)(1), 

Fuel requirement.s.forflight in UFR conditions. Sinclair submits that safety will not be 

6 
affected by terminating flights of the battery powercd Nova F6500 UA after 90 minutes of 

continuous operation or with 20% remaining battery power, whichever occurs first. 

In aecordanee with 14 CFR Section 11.81, Sinclair provides the following 

information in suppoi•t of its petition for exemption: 

A. Name And Address Of "I'he Petitioner. 

The name and address of the Petitioner is: 

Sinclair Community Collel;e 

Dayton Campus 

444 West '1'hird Street 

Dayton, Ohio 45402-1460 

The point of contact for this Petition and specific contact infoemation is as follows: 

Jeffi•ey A. Miller, 

Assistant Vice President, 

Workforce Development 

Sinclair Community College 

Phone 937.512.4848 

B. The Specific Sections Of 14 CFR From Which Sinclair Seeks Exeniption. 

1. Sinclair Seeks Exemption From The Requirements Of Section 91.151(a)(1). 

Section 91.151, entitled Fuel requirements for,flight in VFR conditions, subsection (a)(1), 

states the following: 

(a) No per•son inay begin cr flight !n ctn airplcrne under VFR conditions unless 

(considering wind andjbrecast weather conditions) Ihere is enough fuel to f.y to the 

ftt•st point oT intended landing and, as•suming normal cruising speed-- 

(1) During the day, to fly afler that foi -at least 30 minutes[J 

2. Sinclair Seeks Exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance reduired, subsection (a), states the following: 

Each owner or operator of an air•cf-ctft— 

(a) Shall have that aircraft inspecled as prescribed in subpart E of this part and 

shall behveen reguired inspections, except as provided in paragraph (c) of this 

section, have cliscr•epancies repaired as prescr•ibed in part 43 of'this chapter[.J 

3. Sinclair Seeks Exemption From The Requirements Of Section 91.407(a)(1). 

Section 91.407, entitled Operation c~er nzaintenance, preventive naaintenance, rebuilding, or 

allet•ation, subsection (a)(1), states the following: 
(a) No per-son may oper-ate any aircraft that has undergone maintenance, 

preventive maintenance, rebuilding, or alteration unless-- 

(1) It has been approved for return to service by a person authorized under Section 

43.7 of this chapter[] 

4. Sinclair Seeks Exenlption From The Requirements Of Sections 91.409(a)(1) 

and 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the foIlowing: 

(a) Except as provided in paragr-aph (c) of this section, no person may operate an 

aireraft unless, within the preceding 12 calendar months, it has had -- 

(1)An annual inspection in accof-danee with part 43 of thfs chapter and has been 

approved for return to servfce by a person aaithorized by Section 43.7 of this chapter; 

or 

(2)An inspection, for the issuance of an airwot-thiness certifrcate in accordance with 

part 21 of this chapter. 

5. Sinclair Seeks Exeniption From The Requirements Of Sections 91.417(a) and 

91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the 

following: 

(a) Except for work peyforined in accordance with Sections 91.411 and 91.413, each 

registered oNmer or oper-ator shall keep the followfng records for the perfods spectfled 

in paragraph 

(b) of this seclion: 

(1) Records of the maintenance, preventfve maintenance, and alteration and records of 

the 100-how-, annual, progressive, and other required or approved inspections, as 

appropr-iate, fof- each afrcrafl (including the aitframe) and each engine, propeller, 

rotor, and appliance ofan aircraft. The recor-ds must include-- 

(f) A descs-iption (or reference to data acceptable to the Administrator) of the 

work pei formed; and 

(ii) The date of completion of the work performed; and 

(iii) The sfgnatatre and certificate number- of the person approving the aircraft for 

return to service. 

(2) Records containing the following information: 
(i) The total lirne in service of the airfi-anie, each engine, each propeller, and each 

rolor. 

(ii) The current status of life-limited parts of each airft•ame, engine, propeller, rolor, 

and appliance. 

(iii) The time since last overhaul of all items ins alled on the airci•cft which are 

required to be overhatrled on a specifred time basis. 

(iv) The ezrrrent inspeclion status of the aircraft, including the lirrre since the last 

inspeclion reqiuir•ed by the inspection pr-ogram under which the aircraJt and its 

appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety 

directives including, for each, the method of compliance, the AD or .safety directive 

number and revision date. If the AD or safety directive involves recurring action, the 

time and date when the next action is required. 

(vi) Copies of the forms prescribed by Section 43.9(d) of this chapter for each mcjor 

alteration to the ait•fi•ame and currently installed engines, rolors, propellers, and 

appliances. 

(b) The owner or operator shall retain the following records fo,• the per•iods prescribed: 

(1) The recor•ds specifted in paragraph (a)(1) of this section shall be relained unlil the 

ivork is repeated or supe -seded by olher work or for 1 year afler• the work is 

per; formed. 

(2) The records specffied in paragraph (a)(2) of this section shall be retained 

and transferred with the aircr-aft at the time the ai,rcr•aft is sold 

(3) A list qf defects furnished to a registered owner• oa• operator under Section 

43.11 of this chapter shall be retained until the defects ar-e repair-ed and the 

aircraft is approved for relarrn to service. 

C. The Extent Of Relief Sinclair Seeks And The Reason Sinclair Seeks The Relief. 

1. Extent of Relief Sinclair Seeks And The Reason Sinclair Seeks Relief From 

Section 91 .151(a)(1). 

Relief froin Section 91.151(a)(1) is requested to the extent required to allow flights of 

the batteiy powered Nova F6500 UA during daylight hours under visual flight rules (VFR) in 

visual meteorological conditions (VMC) to continue for a total duration of 90 minutes, or until 

9 
20% battery power is remaining (whichever occurs first). Sinclair seeks the requested relief 

because without an exemption fi•om Section 91.151(a)(1), the flight tiine duration of the battery 

powered Nova F6500 UA will be reduccd by one tlurd, which would severely consti•ain the 

practicality of any educational researeh and training operations that Sinclair proposes to conduct 

as requested in this petition. 

Sigiuficantly, the technical specifications of the Nova F6500 UAS, the Nova 

Operations Manual, and Sinclair's proposed operating limitations ensure that Sinclair will 

safely operate the battery powered Nova F6500 UA during dayliglit liours under day VFR in 

VMC for a total duration of 90 ininutes, or until 20% battery power is remaining, whichever 

occues first. 

2. Extent of Relief Sinclair Seeks And The Reason Sinclair Seeks Relief From 

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b) only 

apply to aircraft with an ait-vvorthiness certificate, Sinclair requests relief from these Sections 

because the Nova F6500 UAS does not require an airworthiness certificate. The Nova F6500 

UAS meets the conditions of Section 333 for operation without an aii-worthiness certificate. 

Accordingly, Sinclair will use its trained teclinicians to perform maintenance, alterations, or 

preventive maintenance on the UAS using the methods, techniques, and practices prescribed in 

the manufacturer's maintenance manual and as accomplished in the current COAs. 

Furthermore, Sinclair will document and maintain all maintenance records for the Nova F6500 

UAS. This is identical to the pi•ocess Sinclair successfully uses today under the existing COAs. 

Sinee we are requesting relief from these sections, Section 91.203 (a) and (b), 45.23 (b), 21.185 

and 91.9(b) also would not apply. 

D. The Reasons Why Granting Sinclair's Request Would Be In The Public Interest 

That Is, How It Would Benefit The Public As a Whole. 

Granting Sinclair's request for a waiver will further the public interest by allowing 

Sinclair to safely, efficiently, and economically perform tJAS educational research and training 

over the KILN airspace under the jurisdiction of the KILN ATC tower under the current MOA, 

shown in Attachment 1. Additionally, use of the Nova F6500 UAS will provide significant 

benefits to the economy by allowing additional training opportunities and further the collection 

of safety data. The data collected would help fui -lhcr the FAA goals of integrating UAS into the 

10 
NAS without reducing existing capacity, decreasing safety, ncgatively impacting cui7•ent 

operators, or increasing the risk to airspace users or persons and property on the ground any 

more than the integration of comparable new and novel technologies, through this 

collaboration. Additionally, the benefits of the proposed operation of the Nova F6500 UAS 

will be realized without implicating any privacy issues. 

1. 'I'he Public Will Benefit From Increased UAS Educational Research. 

Sinclair submits this Petition to perfoim UAS educational research and training. 

Sinclair has an enrollment of 24,000 students. The siiigle-campus college located in downtown 

Dayton, Ohio, is among the largest community college campuses in America. Sinclair is a 

member of the board of the League for Innovation in the Community College. Pait of 

Sinclair's innovative approach is promoting educational research into the future use of UAV 

systems. 

2. The Public Will Benefit From increased UAS T'rainitig Within The NAS. 

The mission of Sinclair's Workforce Development Division is the training of a viable 

workforce for the community with the skills necessary for future achievement. Sinclair's 

Workforce Development Division, UAS IIranch provides practical, real-world applications of 

UAS technologies through classroom instruction, cutting-edge simulation training ancl handson vehicle operations. 

By operating the Nova F6500 UAS, Sinclair will be able to perforni safe, efficient, and 

econoinical aerial educational operations that will directly benefit the public. Specifically, the 

Nova F6500 UAS will be used to further the training is the proper use of UAVs in commercial 

applications. 

3. Performing Educational Research and Training With The Nova F6500 UAS 

Will Benefit The Economy. 

In addition to being safe and efficient, the Nova F6500 UAS is also an economical 

alternative to using manned aircraft to conduct aerial educational research and training. As 

such, operation of the Nova F6500 UAS will allow United States based companies to remain 

competitive and contribute to growtli of the U.S. economy. Educational institutions, like 

Sinclair, will benefit by remaining relevant and on the leading edge of technology advances 

in UAS, as UAS systems become more prevalent in commercial applications, taking the place 

of niany, previously manned flight applications due to rising costs. Specifically, with the high 

cost of aviation fuel and the Environrnental Protection Agency (EPA) regulatory actions 
phasing out leaded fiiels, U.S. owned and operated companies must adopt new and alternative 

technology in order to remain competitive. Operating the battery powered Nova F6500 UAS 

is one such technology that not only allows companies greater operational flexibility 

compared to manned airci-aft, but provides such flexibility without the high operational cost 

of a traditional manned aircraft. 

By operating the Nova F6500 UAS, companies can remain competitive and profitable, 

and therefore provide greater job stability to employees and contractors, which will ultimately 

contribute to growth of the U.S. economy. Improved financial perfoimance of U.S. 

companies, through commercial use of the Nova F6500 UAS, provides a stable workforce 

that increases consumer spending; improves local, state, and federal tax revenues; and allows 

companies to invest in research and development in order to remain competitive both in the 

United States and abroad. 

In order for these companies to employ competent persormel safely, these employees 

and contractors must i-eceive training from established institutions like Sinclair. By having 

institutions like Sinelair accomplish the training, the FAA benefits from the data available on 

small UAS (under 55 pounds), in fuirthering the FAA UAS Roadmap. 

4. There Are No Privacy Issues. 

Like the manned aerial flight operations that have been conducted for decades, the 

proposed operation of the Nova F6500 UAS will not implicate any privacy issues. Specifically, 

the Nova F6500 UAS will be operated in accordance with all Federal Aviation Regulations, 

including the minimum altitude requirements of 14 CFR Section 91.119. Most significantly, 

the Nova F6500 UAS will not be operated closer than 500 feet to any person, vessel, vchicle, 

or structure, except when necessary for takeoff or landing. 

The established rules, currently under the existing COA (2013-CAS-58) will be in force. 

Operation of the Nova F6500 unmanned aircraft system (UAS) in Class D airspace will occur at 

or below 2,500 feet mean sea level (MSL) in KILN airspace under the jurisdiction of KILN ATC 

tower. See COA at Attachment 2. 

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety 

Or How The Exemption Would Provide A Level Of Safety At Least Eclual To That Provided 

By The Rule From Which Sinclair Seeks Exemption. 

12 
1. Reasons Why The Nova F6500 UAS Meets The Conditions Of The 

FAA Modernization and Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with 

the UA and its operation, Sinclair's operation of the Nova F6500 UAS meets the conditions 

of FMRA Seetion 333, and will not require an airworthiness certificate in accordance with 

14 CFR Part 21, Subpart H. 

Section 333 provides authority for UAS to operate without airworthiness certification 

and sets forth requirements for considering whether a UAS will create a hazard to users of the 

NAS or the public, or otherwise pose a threat to national secwity. Specifically, FMRA Section 

333 states the following, in part: 

(a) In General.--Notr>>ithstanding any other requirement of this subtitle, and not later 

than 180 days after the date of enactment of this Act, the Secretar•y of Ti-ansportation 

shall determine if certain unmanned afrcraft systems may operate safely in the 

national airspace system before completion of the plan and rulemaking required by 

Section 332 of this Act or the guidance requfred by Sectfon 334 of this Act. 

(b) Assessment of Unmanned Aircrafi Systems.--In rnaking the determination 

under subsection (a), the Secretary shall determine, at a minimum-- 

(1) which types of'unmanned aircraft systems, if any, as a result of their size, 

weight, speed, operatfonal capability, proximity to airports and populated areas, and 

operatfon within visual line of sight do not create a hazar d to users of the national 

airspace system or the public or pose a thr-eat to national security; and 

(2) whether a certificate of waaver, certificate of authorization, or airworthiness 

certification under Section 44704 of Title 49, United States Code, is required for the 

operatfon of unmanned aircraf systems identified under paragraph (1). 

(c) IZequirements for Safe Operation.--If the Secretary determines under this section 

that certain untnanned aircraft syslems may operate safely in the national airspace 

system, the Secretary shall establish requfrements for- the safe operation of such 

aircraft systems in the national af:-space system. 

In seeking this exemption, Sinclair submits that the Nova F6500 UAS can operate 

safely in the NAS in accordance with FMRA Section 333, as demonstrated by: (a) the safe 

operational history and cun•ent use of the Nova F6500 UAS in the NAS; (b) the inherent 

characteristics of the Nova F6500 UAS; (c) the limited area of Sinclair's intended opei-ation; 

(d) the Private Pilot certification requirements for the PIC; and, (e) the specific operating 

limitations. 

13 
The Nova F6500 UAS Has A Proven History Of Operation In The 

NAS In Accordance With the cui7•ent Ceilificate Of Authorization (COA). 

The Nova F6500 UAS is eurrently operating safely in the NAS in accordance with the 

cui7-ent COA granted by the FAA to Sinclair Convnunity Collegc, in the requested KILN 

airspace. 

b. The Specifications Of The Nova F6500 UAS Demonstrate Its Safe 

Characteristics. 

The Nova F6500 UAS does not create a hazard to users of the NAS or the public, 

or otherwise pose a threat to national security considering its size, weight, speed, or 

operational capability. 

i. Technical Specifications of the Nova F6500 UAS. 

Uiunanned Aircraft 

System (UAS) The Nova F6500 is a UAS comprised of an urunanned aircraft (UA) and 

a transportable ground control station (GCS) 

Serial No. Current: 3009, 3010 Reserved with Manufacturer: 3027, 3028, 3029, 3030 

UA Wingspan: 108 in. 

Dimensions Length: 65 in. 

Engine ine Pro u ive nit 

(1) Altavian, lnc. P/N : 30027 (Electric) (Propulsive Unit) 

FAA Engine 'rype Cert: None 

Propulsive Unit 'fypc: 25V, 11 amp hour capacity, Lithium Ion 

batteiy powered, direct drive electric motor 

Motor. Electric Sub-Assembl : 

Manufacturer: NeuMotor Model: 1509 

2.0 HP Peak Power Direct Drive 10 oz. weight 

Motor, Controller Sub-t\ssembly: 

Manufacturer: Castle Creation 

Model: Phoenix Ice 100 

Type: Speed controller 100 amps maximum 4.6 oz. weight 

Motor, Battery: 

Manufacturer: MaxAmps, Inc. 

Type: Lithium Ion I 1 amp hour, 22.2V (nominal) 

14 
Fuel Not Applicable 

NOTE: Nova F6500 UAS is powei•ed by a Lithium Polymer 

rechargeable battery, Altavian, Inc. P/N 30142 

Engine Maximum power output: 2.0 1IP 

(Propulsive Unit) Maximum RPM: 60,000 RPM (reduced to 7,200 propeller RPM) 

Limits Maximum motor temp.: 170 °F (77 °C) 

NOTE: Motor temp. not displayed to the operator 

Maxinium motor, controller sub-assembly temp.: 194 °F (90 °C) 

Minimuni voltage, motor battery during pre-flight engine run up 

after 3 sec. at max throttle: 22.6V 

Propeller and (1) Altavian, tnc. P/N 30360 

Propeller Limits FAA Propeller Type Certificate: None 

Propeller Type: 2-blade, hinged (folding), carbon fiber reinforced 

plastic, fixed pitch, tractor 

Propeller Sub-Assembly: 

Manufaeturer: Aeronaut 

Model: CAM I Sx 13 

Diameter (Nominal): 15 in. 

Battery Nova Air Vehicle Battery P/N 30142 powers the motor and battery 

Command & Control command and control. 

Airspeed Limits Vne (Never Exceed Speed) 58 knots (30 m/s) 

Vno (Maximum Structural Cruising Speed) 48 knots (25 m/s) 

Va (Maneuvering Speed) 48 knots (25 m/s) 

Landing Speed: 27 knots (14 m/s) 

Etnpty Weight 20.2 — 21.7 in. aft of datum 

C.G. Range 

Datum Front of Motor Case 

Mean Aerodynamic 13 in. long with leading edge 21.2 in. from nose 

Chord (MAC) 

Leveling Means Not Applicable 

Maximum Weights Ramp 151bs. 

Takeoff 15 lbs. 

Landing 15 lbs. 

15 
Enipty Weiglit 8.351bs. 

NOTE: Excludes weiglit of battery and payload modules. 

Frequencies 902-928 MHz (ISM Band) 2.4 

GHz (ISM Band) 

NOTE: FCC license is not required to utilize the above 

frequencies; uplink and downlink are on 900Mhz band. If video 

is utilized, uplink, downlink, and video are on 2.4 Ghz 

Computer Software Avionics embedded processor 

Minimum Crew (1) The Nova F6500 UAS can be operated by a single operator 

Number of Seats Not Applicable 

Fuel Capacity Not Applicable 

Oil Capacity Not Applicable 

Maximum Operating 1,000 ft (304 m) AGL 

Altitude 

Control Surface Wing Flaps N/A 

Movements Ailerons Up 30° Down 30° 

"V" tail elevator action Up 60° Down 60° 

"V" tail rudder action Up 60° Down 60° 

"V" tail max. combination 

Rudder elevator action Up 60° Down 60° 

Nominal Endurance 90 min. above 32 °F (0 °C) 

45 min. below 32 °F (0 °C) 

Ambient Outside Air Maximum OAT: 120 °F (49 °C) 

Temperature (OAT) Minimtim OAT (At Altitude): -20 °F (-29 °C) 

Wind Limit 19 knots 

Mainteiiance This Nova F6500 UAS must be maintained in accordance with the 

manufacturer's maintenance manual, or later FAA accepted revision. 

H. The Nova F6500 I1AS Autonomous Flight And Navigation 

Modes Cnable The UAS To Remain Within A Defined Operational Area. 

[P. 
A complete deseription of the autonomous modes and metlhods of navigation for the 

Nova F6500 UAS is provided in the Nova F6500 UAS Operator Manual at pages 7-2 

through 74. A copy of the Nova F6500 UAS Operator Manual, containing proprietary 

information, is in Attaclunent 3 and is to be held in a separate file pursuant to 14 CFR 

Section 11.35(b). 

iii. The Nova F6500 UAS Is Designed For Coinplete Autonoiny From 

Launch To Landing Tven In The Unlikely Fvent Of Loss Of The Control Link 

Or Navigation. 

Although a degradation or loss of the control link, and/or degradation or loss of the 

source of navigation, is unlikely, it is a situation that is well plarmed for and therefore, is a 

benign event. The Nova F6500 UA is designed for complete autonomy fi-om launch to 

landing with a line of siglit operator in the loop monitoring the airfi•ame. 

The Nova F6500 UA uses a two-stage failsafe approach for all avionics failure 

conditions, including the event of a loss of communications ("lost 1'uik"). Upon loss of the 

communication signal, the Nova F6500 UA will attenipt to reacquire the link. If after 10 

seconds the link has not been reacquired, the Nova F6500 UA will continue to attempt to 

reacquire the link while maintaining the current altitude and navigating to the home waypoint, 

which is the saine as the location of the GCS. Once at the home waypoint, the Nova F6500 UA 

will loiter while continuing its attenipt to reacquire the link for 300 seconds (to allow for 

rebooting of the GCS, if needed). The Nova F6500 UA will then continue to attempt to reacquire the link while it navigates through the landing procedure. 

Attachments to this Petition coiitain proprietary information, and in accordance 

with 14 CFR Section 11.35(b), are not to be included in the Federal Docket Management 

System (FDMS). 

The landing proeedure for Lost Link is identical to a normal landing procedure. The 

Nova F6500 UA will descend from "minimum safe altitude" to a breakout altitude (site 

specific) while continuing to loitet -around the rally point. Once at the breakout altitude, the 

Nova F6500 UA will depail the loiter along a tangential path toward the touclidown spot. The 

Nova F6500 UA will descend on glide slope from the tangent point to the touchdown spot, 

slowing down to flare speed (12 m/s) in the final moments before touchdown and 

automatically flare 3 meters above the ground. 

17 
Loss of GPS signal will result in a two tiered recovery approach. Upon loss of a GPS 

signal, the Nova F6500 UA will inimediately enter a loiter orbit in an attempt to reacquire a 

signal. If after 15 seconds, GPS is not reacyuired, the UA will enter tier two. At any time in 

tier one or-two, the PIC can take over with augmented control and utilize its onboard 

magnetometer to navigate back to the home waypoint tlirough dead-reckoning. During this 

failure mode, the VO will call out UA position and movement back to the PIC. Once the UA 

is close enough to resolve orientation, or if operating with a live video payload, the PIC can 

engage manual control and perform a manual landing at the pre-decided landing site. 

If a cascade of failures has occtu-red and Lost-Link has also occurred during tier two, 

the Nova F6500 UA will enter into a loiter-land procedure; descending in a loiter while 

reducing speed until contact with the ground at Ilare speed. During this decent, the Nova 

F6500 UA is still in controlled flight and at touchdown the forward speed sliould not 

exceeded 11 m/s with the propeller off, minimizing damage to anything that the Nova F6500 

UA may contact. 

The Nova F6500 UAS Operator Manual, Attachment 3, at Chapter 9"Emergency 

Procedures" fully describes the features of the Nova F6500 UA and sets forth its operation in 

the event of a power loss, loss of communications, loss GPS, loss of video link, or software 

crash. A copy of Nova F6500 UAS Operator Manual, containing proprietaiy information, is 

in Attachment 3 and is to be held in a separate file pursuant to 14 CFR Section 11.35(b). 

Additional Lost Link Procedures are included in Attachments 2. 

iv. The Nova F6500 Ground Control Station (GCS) and its 

Operation. 

A complete description of the operation and specifications of the GCS and flight 

control software for the Nova F6500 UAS is provided in the Nova F6500 UAS Operator 

Manual at Chapter 2. A complete overview of the features and operation of the GCS 

software is provided at Chaptcr 7. A copy of the Nova F6500 UAS Opei -ator Manual, 

containing proprietary information, is in Attachment 3 and is to be held in a separate file 

ptirsuant to 14 CFR Section 11.35(b). Additional Ground Station Procedures are included in 

Attaclunents 2. 

C. Flight Operations Of 1he Nova F6500 UAS Are Conducted Within Visual Line 

Of Sight (VI.OS) Of A Ceil:ificated Private Pilot PIC With A Visual Observer (VO). 

18 
Sinclair will only utilize certificated Private Pilots who possess a valid Second Class 

Aii-nian Medical Certificate to act as P1C of the Nova F6500 UAS. Additionally, a visual 

observer (VO) will assist all pilots. Both the P1C and VO must complete the Sinclair Nova 

Operator's Course and meet the experience requirements as set forth in the Nova Family of 

Systems Operations Manual. A copy of the Nova Family of Systems Operations Manual, 

containing proprietary information, is in Attachment 3 and is to be held in a separate file 

pursuant to 14 CFR Section 11.35(b). Furthermore, all flight operations will be conducted in 

accordance with 14 CFR Section 91.119, Minimum safe altitudes: General. 

Figure 2: Cincinnati 'TAC vicw of K1LN. 

d. Flights Will Be Conducted Under SpeciPic Operating Limitations. 

In seeking this exemption, Sinclair proposes to commercially operate the Nova 

F6500 UAS for the spccial purpose of educational research and training: 

19 
1. Flight operations are permitted only in the defined areas over the KILN 

Class D airspace and surrounding Class G airspace as is currently used in the 

existing COA (Attachment 2). 

2. The Nova F6500 UA will be operated at or below 3,577 ft MSL, 

except as necessary to comply with the requirements of 14 CFR Section 91.119. 

3. The Nova F6500 UA will be operated within one mile, and within 

VLOS, of the PIC and VO. 

4. The Nova F6500 UA will be operated under day VFR in VMC. The 

Nova F6500 UAS will be operated only during daylight hours (i.e. between the 

end of morning civil twilight and the beginning of evening civil twilight, as 

published in the American Air Almanac, converted to local time). 

5. Flights of the Nova F6500 UA will continue for a total duration of 

90 minutes, or until 20% battery power is remaining, whichever occurs first. 

6. The Nova F6500 UA will operate from on-site takeoff/landing 

location(s) directly next to the PIC and co-located VO. If the operation is fiom a 

watercraft, the PIC and VO will remain co-located on the same watercraft. 

7. Private pilot certificated airmen, who have completed training, 

checking, currency, will conduct operations and recency of experience 

requirements as approved by t,he FAA Administrator. 

8. Operation of the Nova F6500 UAS with any inoperative 

instruments or equipment shall be prohibited. 

9. The Nova F6500 UAS will be maintained in accordance with the 

manufacturer's Maintenance Manual. 

10. The Nova F6500 UAS will be operated pursuant to 14 CFR Part 

91, General Operatfng and Flighl Rules. 

11. For the proposed flight operation, only one Nova F6500 UA shall be 

aii•borne at any given time. 

12. Prior to flight operations, Sinclair will coordinate and 

establish two-way communications with the nearest ATC facility. 

13. For any flight operations over U.S. Government or state managed 

lands, Sinclair will coordinate with the appropriate authority and ensure that the 

property owners have at least twelve (12) hours of advance notice prior to the 

20 
proposed flight operations. Coordination shall include anticipated periods of 

operation, purpose of the flights, and contact information for the PIC should 

questions or issues arise. 

2. Reasons Wliy An Exemption From The Requirements Of Section 91.151(a)(1) 

Would Not Advet•sely Affect Safety. 

A grant of this exemption would ensure the level of safety established by 14 CFR 

Section 91.151(a)(1) because the technical specifications of the Nova F6500 UAS, the Nova 

Operations Manual, and Sinclair's proposed operating limitations ensure that Sinclair may 

safely operate the battery powered Nova F6500 UA under day VFR in VMC for a total 

duration of 90 minutes, or unti120% battery power is remaining, whichever occurs first. 

Furthermore, previous exemptions granted by the FAA concerning Section 91.151(a)( l) 

establish that safety is not adversely affected when the technical characteristics and operating 

liinitations of a UAS are considered. 

The Nova F6500 UA is powered by a I,ithium Ion 11 amp hour, 22.2 V battery, and is 

protected by two low battery failsafes, while the GCS provides a battery indicator on the 

lieads-up display, whicli indicates the remaining batteiy power of the Nova F6500 UA 

measured in Volts, providing the PIC with constant awareness of the real-time battery voltage 

during a flight. 

The two low battery failsafes that protect the Nova F6500 UA are a"Low AV 

battery" failsafe and a"Critically low AV battery" failsafe. The "Low AV battery" failsafe 

flies the UA to the location of the GCS, or identified Rally point, when the UA batteiy 

reaches a certain threshold of time as configured by the operator, or 20.4V. The "Critically 

low AV battery" shuts the propulsion motor off and lands the UA at its current location. 

This failsafe is triggered if the battery drops below the critical batteiy voltage as configured 

by the operator, or 19.4V. 

Furthermore, an exemption from the requirements of Section 91.151(a)(1) would not 

adversely affect safety because Sinclair will only conduct fliglits undei• day VFR in VMC, 

with the duration of each flight not to exceed 90 minutes, as set forth by the Nova Family of 

Systems Operations Manual. A copy of the Nova Family of Systems Operations Manual, 

Attachment 3, contains proprietary information and is to be held in a separate file pursuant to 

14 CFR Section 11.35(b). 

21 
Likewise, as set forth above, Sinclair has proposed specific operating (iinitations in 

this Petition that will maintain the level of safety established by Section 91.151(a)(1), 

including the following: (1) the Nova F6500 UA will only be operated during dayliglit hours 

(i.e. between the end of morning civil twilight and the beginning of evening civil twilight, as 

published in the American Air Almanac, converted to local time); (2) Nova F6500 UA will 

only be operated pursuant to day VFR in VMC; and (3) the divation of each flight shall not 

exceed 90 minutes or 20% of batteiy life remaining, whichever occurs first. 

Significantly, previous exemptions granted by the FAA concerning Section 

91.151(a)(1) establish that safety is not adversely affected when the technical characteristics 

and operating limitations of the UAS are considered. Relief has been granted for manned 

aircraft to operate at less than the minimums prescribed in Section 91.151(a), including 

Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief 

from Section 91.151(a)(1), specific to UAS, in circumstances similar to those presented here 

(e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 

11067, 11080). 

3. Reasons Why An Exemption From The Requirements Of Sections 

91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b) 

Would Not Adversely Affect Safety. 

In seeking this exemption, Sinclair submits that the level of safety with regard to the 

regulatory maintenance and alteration requircments established by Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) &(a)(2), 91.417(a) &(b) will be met because Sinclair, as operator 

of the Nova F6500 UAS, will use its trained technicians to perform maintenance, alterations, 

or preventive maintenance on the iJAS using the methods, techniques, and practices 

prescribed in the manufacturer's maintenance manual, as it does today within the procedures 

set forth in its existing COAs. Furthermore, Sinclair will document and maintain all 

inaintenance records for the Nova F6500 UAS. 

Since the Nova F6500 UAS will be inspected as prescribed by the manufacturer's 

maintenance manual, Sinclair will maintain the level of safety established by Sections 

91.405(a), 91.409(a)(1), and 91.409(a)(2). The Nova F6500 Maintenance Manual sets forth 

Scheduled Maintenance Inspection procedures for each system and component. Inspection 

22 
intervals for the Nova F6500 UAS include preflight and post flight inspections, as well as 

scheduled inspections every 25 hours, 50 hours, 75 liours, and 100 hours. 

Likewise, the exemption sought will not adversely affect safety because Sinclair will 

perform maintenance, alterations or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed by the manufacturer's maintenance manual. The Nova 

F6500 Maintenance Manual details procedures for each component of the UA, including the 

components of the propulsion system, avionics system, payload system, fuselage system, 

wing, and tail. 

The Nova F6500 Maintenance Manual, shown in Attachment 4, contains proprietaiy 

information and is to be held in a separate file pursuant to 14 CFR Section 11.35(b). 

Fuithermore, the exemption sought would maintain the level of safety established by 

Sections 91.407, 91.417(a) and 91.417(b) because all maintenance of the Nova F6500 UAS 

will be performed by trained technicians, who will document and maintain maintenance 

records for the Nova F6500 UAS. Sinclair trained technicians are qualified to conduct any 

and all maintenance to ensure the safe operation of the Nova family of UAS, conduct all 

service inspections, and authorize the use of each vehicle in the Nova family of tJAS based 

upon completion of appropriate inspections. See Nova Fainily of Systems Operations Manual, 

Attachment 3 at page 3-4. In accordance witli the Nova Family of Systems Operations Manual 

and the Nova F6500 Maintenance Manual, a Maintenance Action Form must be completcd 

and saved in the rnaintenance logs for all maintenance that is performed on the UAS. The 

procedures for maintaining the maintenance logs for the UAS are fully set forth in the Nova 

Family of Systems Operations Manual, Attachment 3, at C:hapter 5, and the Nova F6500 

Maintenance Manual, Attachment 4, at Chapter 5. 

Significantly, previous exemptions granted by the FAA concerning Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), 91.417(a) &(b) establish tllat safety is not 

adversely affected when the tecluiical characteristics and operating limitations of a UAS are 

considered. 

4. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with FMRA Section 333 and 14 CFR Section 21.16 entitled Special 

Condilions, Sinclair requests that the FAA prescribe special conditions for the uitended 

opeiration of the Nova F6500 tJAS, which contain such safety standards that the Administrator 

23 
finds necessaiy to establish a level of safety equivalent to that established by 14 CFR Pait 21, 

Subpart H, and 14 CFR Sections 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), 

and 91.417(a) &(b). Such special conditions will perniit safe operation of the UA for the 

limited purpose of educational research and training. FMRA Section 333 sets foi•th the 

requirements for considering whether a UAS will create a hazard to users of the NAS or the 

public, or othervvise pose a tlueat to national security; and further, provides the authority for 

such UAS to operate without airworthiness certification in aeeordance witlt any requirements 

that must be established for the safe operation of the aircraft systems in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 CFR 

Section 21.16, for operation of the Nova F6500 UAS, since the airworthiness regulations 

of 14 CFR Part 21 do not contain adequate or appropriate safety standards, due to the 

novel or unusual desit;n features of the aircraft. Section 21.16, entitled Special Conditions, 

states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain 

adequate or appropriate sufety standards for an aircraft, aircraft engine, or 

pr•opeller• because of a novel or tunusual design feature of the aircraft, crircraft 

engine or propeller, he prescribes special conditions and amendments thereto for 

the product. The special conditions ar•e issued in accot•dance ti>>ith part 11 of 'thi.r 

chapter and contain such scrfety standards for the aircr•aft, aircr•aft engine or 

propeller as the FAA finds necessary to establish a level o,fsafety eqzrivalent to that 

established in the regulations. 

See 14 CFR Section 21.16. 

Therefore, in accoi•dance with FMRA Section 333 and 14 CFR Section 21.16, the 

FAA may prescribe special conditions for Sinelair's intended operation of the Nova F6500 

UAS, which contain such safety standards that the Administrator finds necessary to establish 

a level of safety equivalent to that established by 14 CFR Part 21, Subpart 11. 

F. A Summaiy That Can Be Published In The Federal Register 

stating: 

The Rules From Which Sinclair Seeks Exemption: 

SINCLAIR COMMUNITY COLLEGE seeks exemption fi•om the requirements of 

Part 21 and Sections 45.23(b), 91. 9(b), 91.151(a)(1), 91.203(a) &(b), 91.405(a), 

91.407(a)(1), 91.409(a)(1) &(a)(2), 91.417(a) & (b) of Title 14 CFR. 

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A Brief Description Of The Nature Of The Exemption Sinclair Seelcs: 

This exemption will permit SINCLAIR COMMUNITY COLLEGE to operate an 

unmanned aircrafl ssystem (UAS) for educatfonal research and training, whdle 

Ireepfng the documents r-equired by the regulatfons at the gr•ound control station and 

immediately accessible to the pilot in command. Fztrthermore, the exemption will 

relieve Sinclair Community College from the airwot•thfness certffrcate standards and 

the requirement to have a certfficate of ait•worthiness for its UAS 

G. Any Additional Information, Views, Or Arguments Available To Support Sinelair's 

Request. 

This Petition is made pursuant to FMRA Section 333, which directs the Secretaty of 

Transportation to determine if certain UAS may operate safely in the NAS. As such, 

Sinclair's request for exemption may be granted pursuant to the authority of FMRA Section 

333 and 14 CFR Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will 

create a hazard to users of the NAS or the public, or otherwise pose a threat to national 

security; and fiuther, provides the authority for such UAS to operate without airwortliiness 

certification. 

As discussed in detail above, the Nova F6500 UAS has a strong record of being 

operated in the NAS without creating a hazard to users of the NAS or the public, or 

otherwise posing a threat to national security. Following procedwes outlined in this 

request, Sinclair will continue to safely operate the Nova F6500 UAS in the NAS. 

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CONCLUSION 

As requested, Sinclair seeks an exemption in accordance with 14 CFR Section 11.61 

and FMRA Section 333, which will permit safe commercial operations of the Nova F6500 

UAS, without an airworthiness certificate, for the limited purpose of conducting educational 

research and training in Wilmington Air Park airspace. By granting this Petition, the FAA 

Administrator will be fulfilling the Congressional mandate of P.L. 112-95, while also 

advancing the interests of the public by allowing Sinclair to safely, efCciently, and 

economically operate the Nova F6500 UAS commercially within the NAS. 

Therefore, in accordance with the Federal Aviation Regulations and the FAA 

Modernization and Reform Act of 2012 Section 333, Sinclair respectfully requests that the 

FAA Administrator grant this Petition for an exenlption fi•om the requirements of Part 21 and 

Sections 45.23(b), 91.9(b), 91.151(a)(1), 91.203(a) &(b), 91.405(a), 91.407(a)(1), 

91.409(a)(1) &(a)(2), 91.417(a) &(b) of Title 14 CFR, and permit Sinclair to operate the 

Nova F6500 UAS for the purpose of educational research and training. 

Dated: February 12, 2015 

tted, 

(11~ 

A sistant Vic Presi en`l~ 

orkforce evelo ment 

Sinclair Co u ity College 

26