AFS

- 14

- 330

- E Exemption No. 11114

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC 20591

In the matter of the petition of

WO OLPERT, INC

. Regulatory Docket No. FAA

- 201 4

- 0398

for an exemption from §§ 21.185;

45.23 (b); 91.9(b); 91.203(a) and (b) o f Tit le 14, Code of F ederal Regulations

GRANT OF EXEMPTION

By letter dated June 13, 2 014, Mr. Gregory S. Winton and Mr. Jared M. Allen of The Aviation Law Firm, Counsel for Woolpert, Inc., 1 997 Annapolis Exchange Parkway

, S uite

3 00

, Annapolis, Maryland 2 1401

, petitioned the Federal Aviation Administration (FAA) on behalf of Woolpert, Inc

. (Woolpert) for an e xemption from §§ 21.185, 45.23 (b) , 91.9 (b) , and

91.203 (a) and (b) of Title 14 of the Code of Federal Regulations (14 CFR). The exemption

would allow o peration of unmanned aircraft systems (UAS) for the purpose of precision aerial

surveys over Ship Island, Mississippi

.

The petitioner requests relief from the following regulations:

Section 21 .185 prescribes

, in pertinent part, the procedural requireme nts for issuing restricted category aircraft airworthiness certificates

.

Section 45.23(b) prescribes, in pertinent part, that when marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

spo rt 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 word s “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.2

Section 91.9(b) in pertinent part prohibits operation of U.S.

- registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rot orcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworth iness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in § 47.31(c).

Section 91.203(b) prescribes , in pertinent part, that no person may operate a civil aircraft unless the airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

The petiti oner supports its request with the following information:

The petitioner has provided the following information in its petition and supplemental proprietary e xhibits in support of its request for exemption : 1) Altavian Nova F6500 O perator

M anual, 2) Woolp ert UAS Safety Management System, and 3) Woolpert UAS Operations

Manual (hereafter collectively referred to as the operating documents)

.

The FAA has organized the petitioner’s information into four s ections: 1) the unmanned aircraft system, 2) the UAS Pil ot in Command (PIC), 3) the U AS operating parameters, and 4) public interest.

Unmanned Aircraft System (UAS)

The UAS proposed by the petitioner is an Altavian Nova Block III UAS, Serial No. 3001, registration number N937RW and hereinafter referred to as the Nova Block III . This system is comprised of an unmanned aircraft and a transportable ground station. The Nova Block III has a maximum gross weight of about 15 pounds with a wingspan of 108 inches and a length of 65 inches. It is equipped with a singl e propeller driven by a n electric motor powered by a lithium polymer battery . The petitioner states that an exemption from § 21.185, subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety u nder 14 CFR part 11 and Section 333 of the FAA Modernization and Reform Act of 2012 (P

. L

. 112

- 95) , subject to the following considerations :

• T he safe operational history and current use of the Nova Block III UAS in the national airspace system ( NAS ) ;

• T he characteristics of the Nova Block III UAS (including size, weight, and speed ) ;

• T he limited area s of Woolpert’s intended operations, not in the proximity of airports or over populated areas ;

• Conducting o perations of the Nova Block III UAS pursuant to Woolpe rt ’s Safety Management System;3

• Conducting operations of the Nova Block III UAS within the line of sight of a commercial certificated pilot with a safety observer ; and

• Conducting operations in accordance with the operating limitations identifi ed by Woolpert in its petition

.

The petitioner states that the unmanned aircraft (UA) to be operated under this request flies at a speed of no more than 58 knots, carries neither a pilot nor passenger, and operates exclusively within a limited area as set out in its pe tition. In addition, the petitioner has integrated a variety of operating/safety restrictions into its operations as described in the petitioner’s operating documents to ensure the safety of persons and property within and surrounding the limited operating area. The petitioner further describes that, in the event the UAS loses communications or its GPS signal, the PIC will execute emergency f light

t ermination procedures and notify Air Traffic Control (ATC) , the airspace manager

, and all

local auth orities pe r local requirements.

The petitioner states that even though its UAS will have no airworthiness certificate, an exemption may be needed from 14 CFR 45.23 as the UA will have no entrance to the cabin, cockpit, or pilot station on which the aircraft type ce rtificate can be placed. The petitioner asserts that an equivalent level of safety will be provided by having the UA marked with the word “restricted” on the fuselage in compliance with § 45.23(b), in a location where the pilot, observer, and others worki ng with the UA will see the identification.

The petitioner states that maintenance will be performed by the N ova UAS t echnical l ead and the Pilot in Charge. This include s conducting all maintenance and upkeep required to ensure the safe operation of the N ova Block III and authorizing use of the UA based upon completion of appropriate inspection(s) such as pre

- flight.

UAS Pilot i n Command (PIC)

The petitioner asserts all operations of the NOVA Block III wil l be conducted by a designated

p ilot in c ommand (PIC) who shall hold a current c ommercial p ilot certificate with a valid first

or second class airman medical certificate. In addition to the PIC , the crew is complemented by a safety observer (hereafter the Visual Observer (VO) ) . The V O will initially l aunch the vehicle before turning it over to the PIC, monitor the authorized airspace to identify errant aircraft or unsafe conditions that might exist during the flight, maintain constant verbal communication with the PIC to alert him/her to changing condi tions, and in the event of an emergency, calling the appropriate agency overseeing the airspace.

UAS Operating Parameters

The petitioner states that all flights will be operated pursuant to an agreement with the U.S. Army Corps o f Engineers , coordinati ng petitioner’s operations over Ship Island with the Department of Interior , National Park Service

. The p etitioner has received a S cientific

R esearch and C ollecting P ermit from the National Park Service for all of its flight operations.4

Ship Island is comp rised of two Mississippi barrier islands located about 11 miles south of Gulfport and Biloxi, Mississippi , is part of the Gulf Islands National Seashore

, and is accessible only by boat.

The petitioner also states t hat the Nova Block III UAS can operate sa fely in the NAS above Ship Island without creating a hazard to other aircraft or people on the ground. Further, the petitioner states that the NOVA Block III will be operated within one mile and within visual line of sight (VLOS) of the pilot and safety ob server, and that the UAS will be limited to a

maximum altitude of 400 feet above ground level ( AGL ) , and under day visual flight rules in visual meteorological conditions. Woolpert states in this petition that it seeks to operate its

Nova Block III UAS on ly over Ship Island

.

Public Interest

The petitioner states that granting its petition for exemption will further the public interest by allowing Woolpert to safely, efficiently, and economically perform aerial acq uisition and

research over Ship Island

, while also contributing to research for the U.S. Army Corp s of Engineers. Additionally

, the petitioner states that use of the Nova Block III UAS will decrease congestion of the NAS, reduce pollution, and provide benefits to the economy.

Discussion of P ublic Comments:

A summary of the petition was published in the Federal Register on July 15 , 2014 ( 79 FR 41350 ).

Four commenters, including the Small UAV Coalition (Coalition) , t he Association for Unmanned Vehicle Systems International (AUVSI) and the Ai r Line Pilots Association,

Int ernational (ALPA), submitted comments. The Coalition and AUVSI support ed the petition , whereas ALPA oppose d the petition.

The Coalition state d that Woolpert's petition amply demonstrates that its UAV operations can be

co nducted safely, and thus Woolpert should receive authority under section 333.

AUVSI state d that the FAA has already granted multiple COAs for different public users of

the Nova Block III UAS; therefore, the FAA should already be familiar with its design a nd performance characteristics. AUVSI further state d that Woolpert also plans on utilizing a safety management system, a commercially rated pilot with a valid medical certificate, and a safety observer. AUVSI assert ed that Woolpert's exemption outlines at least an equivalent level of safety over the use of a manned aircraft and that Woolpert has adequately addressed the safety requirements in a number of federal aviation regulations.

ALPA state d that it cannot support the petition without further understa nding and assurances of mitigating measures for the commercial use of UAS in the NAS. ALPA noted four areas that need to be addressed in order to ensure safe operations.5

First, ALPA expressed concerns regarding the reliability, safety and operation of the small

UAS. ALPA stated that the petitioner’s anticipated operations are expected to occur in Class G Airspace b elow 400 feet above the surface. ALPA further state d that the proposed operation would place the small UAS in the same proximate airspace a s manned aircraft operations. ALPA a ssert ed that since the petitioner proposes no separation capabilities to mitigate the risk of collision, the proposed operation increases the likelihood of unanticipated safety impacts to an already burdened NAS. ALPA also state d that there must be means both to ensure that the UA remains within the defined airspace and to ensure that the hazard of other aircraft intruding on the operation is mitigated. These concerns are addressed by the limited scope of Woolpert’s op erations ( only over Ship Island ) along with other conditions

and limitation s including stand

- off distance from clouds, altitude restrictions, the requirement to request a NOTAM, and operating distance from non

- participating personnel. Further detail

is con tained in the analysis of the UAS operating parameters below.

The FAA believes the limitations under which the petitioner will operate (i.e. VLOS and at or below 400 feet AGL) are sufficient mitigations to this risk so that the operations will not

adverse ly affect safety

.

Second, ALPA commented that Communication and Command (C2) (t ypically referred to as

command and contro l ) link failures are one of the most common failures on UAS and lost link mitigations require safe modes to prevent fly

‐ a

‐ ways or othe r scenarios, including mitigations such as, auto

‐ land, return

‐ to

‐ home and geo

‐ fencing boundary protection, incorporated into the navigation and control systems for a UA to safely land or re

‐ establish C2. ALPA further stated that the radio frequency spectru m that is commonly accessed for small UAS is unprotected

and assert ed that mitigations for spectrum interference, weather, terrain and obstacles (man

‐ made or natural) should be developed to ensure safe operations.

The FAA agrees and carefully examined th e proposed operation to ensure that the vehicle design and the petitioner’s supporting documentation addressed potential hazards related to C2 failure. The FAA finds that the UAS to be operated by Woolpert has sufficient design

features to address these ha zards. Further detail is contained in the analysis of the UAS below.

Third, r egarding 14 CFR 91.113 Right of Way, “See an d Avoid” requirements, ALPA stated

that given the absence of an onboard pilot, a means to meet this regulatory requirement is

necessar y. An individual commenter also expressed concerns regarding the ability to see and

avoid. The individual commenter suggested that any exemption should require that Woolpert give right of way to any manned aircraft, including p art 103 ultralights

. The FAA notes these concerns; additional detail is provided in the analysis of the UAS below.

Finally, ALPA assert ed that the FAA’s limited resources may be significantly taxed by the continuing use of waiver requests until such time as the small UAS rule can be promulgated.6

The individual commenter also stated that the FAA should require Woolpert to provide public

notification of the UAS activity at least 24 hours before operation. The commenter also expressed concern regarding : 1) activities outside the curre nt test ranges; 2) UAS registration ; 3 ) operations within VLOS ; and 4 ) the autonomous nature of Woolpert’s UAS

. The FAA has addressed each concern in the FAA analysis section and/or in the conditions and limitations of

this grant of exemption

.

The FAA's analysis is as follows :

Unmanned aircraft system (UAS)

T he petitioner requested relief from 14 CFR part 21 Certification procedures for products and

parts

. In accordance with the statutory criteria provided in Section 333 of P.L. 112

- 95 in

reference to 4 9 USC § 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. Because the Se cretary of Transportation has determined that no airworthiness certificate is required

, the requested relief

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

, is not

necessary.

Aerial survey operations with manned aircraf t are typically conducted with aircraft holding

standard airworthiness certificates issued under part 21, subpart H. These aircraft are normally

modified via the s upplemental t ype c ertificate (STC) process to install cameras and other equipment not include d in the original aircraft design.

Manned aircraft conducting aerial surveying operations can weigh 5,000 to 7,000 lbs. or more

, are operated by an onboard pilot and may carry other onboard crewmembers, as well as carry 100

- 200 gallons or more of fuel . T he petitioner’s UA will weigh less than 15 lbs. The pilot and crew will be remotely located from the aircraft. The limited weight and construction reduces the potential for harm to persons or damage to property in the event of an incident or

accident. T he risk to an onboard pilot and crew during an incident or accident is negligible with the use of a UAS for the aerial surveying operation.

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The

Nova Block III carries no fuel and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated.

The FAA notes that the petitioner’s UAS has the capability to operate safely after experiencing certain in

- flight contingencies or failur es and uses an auto

- pilot system to maintain UAS stability and control. The UAS is also able to respond to a loss of GPS or a

lost

- link event with pre

- coordinated automated flight maneuver s

.

Regarding the petitioner’s requested relief from 14 CFR 45.23 (b) Display of marks, the petitioner requests this relief under the assumption that marking with the word “ restricted ”7

will be required as a condition of a grant of exemption. However, this marking is reserved for

aircraft that are issued restricted certif icates under 14 CFR 21.1 85 . The petitioner’s UAS will

not be certificated under § 21.1 85 , and therefore the “ restricted ” marking is not required. Since the petitioner’s UAS will not be certificated under § 21. 185 , a grant of exemption for § 45.23(b) is no t necessary

.

Pilot i n Command (PIC) of the UAS

The PIC will be a current commercially rated pilot and hold a valid first or second class

airman medical certificate and comply with a ll training and currency requirements in the operating documents , prio r t o operations.

Operating parameters of the UAS

Regarding the petitioner’s requested relief from §§ 91.9(b)(2) Civil aircraft flight manual, marking, and placard requirements and 91.203(a) and (b) Civil aircraft: Certifications required

, the FAA has previou sly determined that relief from these sections is not necessary. Relevant materials may be kept in a location accessible to the PIC in compliance with the regulations. T he operating documents are an acceptable equivalent to the manual materials

referenced in 14 CFR 91.9(b)(2) and adherence to the procedures within th e operating

documents are required through the conditions and limitations below.

The petitioner did not seek relief from 14 CFR 91.119 Minimum safe altitudes: General. However, the petitione r states that it will operate the Nova Block III UA at or below 400 feet

AGL

.

The FAA has reviewed the petitioner ’ s operating parameters and finds that they are not sufficient to comply with § 91.119(c) which prohibits operations closer than 500 feet to a ny person, vessel, vehicle, or structure. Ship Island contains structures and public access to the

island. Consistent with § 91.119(c), a ll nonparticipating persons, vessels, vehicles, and structures will be required to be at least 500 feet from flight o perations. However, the FAA finds that the UA may be operated at distances less than 500 feet from unoccupied vessels, vehicles or structures owned by the land owner/controller when the land owner/controller grants such permission and operation closer to t hese structures presents no safety hazard to nonparticipating persons or property. With regard to operations in proximity of the PIC and VO, the UA may be operated closer than 500 feet when operationally necessary. However at no time can operations be con ducted so close as to present an undue hazard to the PIC or VO,

per § 91.119(a).

The FAA finds that relief from § 91.119(c) to permit operations closer than 500 feet to participating persons, vessels, vehicles and structures, is warranted provided adheren ce to the procedures in the operating documents and the FAA’s additional conditions and limitations

outlined below.8

Additionally, in evaluating the petitioner’s proposed operating parameters with regard to VLOS and a safe operating perimeter, the FAA cons idered operations from a moving device or vehicle. Since the petitioner did not discuss provisions for these circumstances, the conditions and limitations below p rohibit operations from moving devices or vehicles.

Regarding an Air Traffic Organization (AT O)

- issued Certificate of Waiver or Authorization (COA), Section 333 of P.L. 112

- 95 states , in pertinent part, that a determination must be made regarding which types of UAS operations do not create a hazard to users of the NAS. The majority of current UAS operations occurring in the NAS are being coordinated through ATC by the issuance of a COA. This is an existing process that not only makes local ATC facilities aware of UAS operations, but also provides ATC the ability to consider airspace issues that

a re unique to UAS operations. The COA will require the operator to request a NOTAM, which is the mechanism for alerting other users of the NAS to the UAS activities being conducted. Therefore, the FAA believes that adherence to this process is the safest and most expeditious way to permit Woolpert to conduct its proposed UAS operations. The conditions and limitations below prescribe the requirement for Woolpert to obtain an ATO

- issued COA.

Public Interest

The FAA finds that a grant of exemption is in th e public interest. The enhanced safety achieved using a 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 fu el, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

The table below summarizes the FAA’s determinations regarding the relief sought by the petitioner:

Relief considered (14 CFR) FAA determinatio n (14 CFR)

21.185 Relief not necessary 45.23(b) Relief not necessary 91.9(b)(2) Relief not necessary

91.119 (c) Relief granted with conditions and limitations 91.203(a) and (b) Relief not necessary

The FAA’s Decision

In consideration of the fo regoing, 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, Woolpert, Inc

. is granted an exemption from 14 CFR

91.119 (c ) t o the extent necessary to allow Woolpert to operate the Altavian Nova Block III unmanned aircraft system for the special purpose of precision aerial surveys that consist of still photographs taken by an onboard camera

. This exemption is subject to the conditions and

limitations listed below.9

Conditions and Limitations

Relative to this grant of exemption, Woolpert is hereafter referred to as the o perator.

The Woolpert UAS Safety Management System

, the Woolpert UAS Oper a tions Manual , and

the Altavian N ova F6500 Operator Manual are hereafter collectively referred to as the operating documents

.

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 exempti on.

1) Operations authorized by this grant of exemption are limited to the following aircraft

described in the operating documents which is a fixed

- wing aircraft weighing less

than 15 pound s : Woolpert Altavian Nova Block III (Nova Block III ) . Proposed
operat ions of any other aircraft will require a new petition or a petition to amend this
grant.

2) The N ova Block III UA may not be flown at a n indicated airspeed exceeding 58

knots.

3) The N ova Block III UA must be operated at an altitude of no more than 40 0 feet

a bove ground level (AGL) . All altitudes reported to ATC must be in feet

.

4) The N ova Block I II UA must be operated within visual line of sight (VLOS) of the

Pilot i n Command ( PIC ) at all times. This requires the PIC to be able to use human vision unaided by a ny device other than corrective lenses, as specified on the PIC’s

FAA

- issued airman medical certificate.

5) All operations must utilize a Visual O bserver (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capabi lity. The VO and PIC must be able to communicate verbally at all times. 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 functions prescr ibed

in the operating documents

.

6) The operating documents and this grant of exemption must be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedur es 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 operatin g documents

. It is the operator’s responsibility to track such revisions and present updated and revised documents to10

the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment t o this grant of exemption . If the operator determines that any update or revi sion would affect the basis upon which the FAA granted this exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (A FS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents

.

7) Prior to each flight the PIC must inspect the N ova Block III UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition th at affects the safe operation of the N ova Block III UAS, the N ova Block III UA is prohibited from operating until the necessary maintenance has been performed and the N ova Block III UAS is found to be in a condition for safe flight. The N ova Block III Grou nd Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records

.

8) Any N ova Block III UAS 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. The PIC who conducts the functional test flight must make an entry in the N ova Block III UA aircraft record of the flight.

9) In addition to the pre

- flight inspection section in the operating documents , t he preflight inspection must also account for all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents

.

10) The operator must follow the N o va Block III manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

11) The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating d ocuments

. Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight hours, description of work accomplished, and the signature of the authorized N ova Block III

Technical Lead or PIC returning the N ova Block III UAS to service.

12) The operator’s N ova Block III Technical Lead or PIC must make a record entry in the UAS logbook or equivalent document of the corrective action taken against discrepancies discovered between inspections.

13) The operator’s N ova Block III Tec hnical Lead

, PIC , and VO, must receive and document training referenced in the operating documents

.

14) The UAS operated under this exemption must comply with all manufacturer System

and S afety Bulletins.11

15) The PIC must possess at least a FAA

- issued commercial pilot certificate and a valid

FAA

- issued first or second class airman medical certificate . 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.

16) Prior to operating for hire, t he PIC and VO must have successfully completed Woolpert ’s t raining s yllabus as outlined in the operating documents

. In addition, the

PIC and VO must also have successfully completed a nnual (recurrent) t raining in

accordance with the operating documents . A record of training must be documented and made available upon request by the Administrator

. Training, proficiency, and experience

- building flights for the purpose of training pilots and VOs to conduct flights authorized by this exem ption are permitted under the terms of this exemption

.

17) If the N ova Block III UA loses communications or loses its GPS signal, it must return
to a pre

- determined location within the planned operating area and land or be

recovered in accordance with the o perating documents

.

18) The PIC must abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents

.

19) The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization ( COA) prior to conducting any operations under this grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.

20) The N ova Block III UA 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.

21) Before conducting operations, the r adio frequency spectrum used for operation and

control of the N ova Block III UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

22) The documents required under14 CFR 91.9 and 91.203 must be available to the PIC

at the Ground Control Station of the N ova Block III UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.

23) The N ova Block III UA must remain clear and yield the r ight of way to all other

aircraft operations and activities at all times.

24) The N ova Block III UAS may not be operated from any moving device or vehicle.12

25) N ova Block III UAS operations may not be conducted during night, as def ined in

14 CFR 1.1

.

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

The N ova Block III UA m a y not be op era t e d l e ss th a n 500 fee t b e low or l e ss th a n 2,000 fee t ho r i z ont a lly fr om a c loud or wh e n visibility is l e ss th a n 3 st a tu te mil e s fr om the P I C

.

27) Operations under this grant of exemption are limited to Ship Island and its immediate surrounding waters.

28) O peration of the N ova Block III UA must be conducted at least 500 feet from all persons, vessels, vehicles, and structures n ot directly involved in the operation

.

29) Operations of the UA may be conducted at distances less than 500 feet from participating persons, vessels, vehicles or structures that perform an essential function in connection with these special purpose operation s. Operations closer than 500 feet from the PIC, VO, operator trainees and essential persons, are permitted when operationally necessary; but never so close as to present an undue hazard, per § 91.119(a).

30) Operations of the UA may be conducted at distances less than 500 feet from unoccupied vessels, vehicles or structures owned by the land owner/controller when the land owner/controller grants such permission and the PIC makes a safety assessment of the risk from operations closer to these objects.

31) All ope rations shall be conducted with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

32) 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 meeting the requirements of 49 CFR part 830 mus t be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.13

Unless otherwise specified in this grant of exemption, the unmanned aircraft system (UAS)

, pilot in command (PIC)

, and ope rator must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61

, and 91.

This exemption terminates on December 31, 201 6

, unless sooner superseded or rescinded.

Issued in Washington, DC, on December 10, 2014.

/s/

John S. Duncan
Director, Flight Standards Service