AFS-14-383-E

Exemption No. 11111

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 20591

 

In the matter of the petition of 

 

WOOLPERT, INC. Regulatory Docket No. FAA-2014-0506

 

for an exemption from §§ 21.185;

45.23(b); 91.9(b); 91.203(a) and 

91.203(b) of Title 14, Code of Federal 

Regulations 

 

GRANT OF EXEMPTION

 By letter dated July 17, 2014, Mr. Gregory S. Winton and Mr. Jared M. Allen of The 

Aviation Law Firm, Counsel for Woolpert, Inc., 1997 Annapolis Exchange Parkway, Suite 

300, Annapolis, Maryland 21401, petitioned the Federal Aviation Administration (FAA) on 

behalf of Woolpert, Inc. (Woolpert) for an exemption 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 operation of unmanned aircraft systems (UAS) for the purpose of precision aerial 

surveys. 

The petitioner requests relief from the following regulations:

Section 21.185 prescribes, in pertinent part, the procedural requirements 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 lightsport category aircraft or experimental or provisionally certificated aircraft, the operator 

must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the words “limited,” 

“restricted,” “light-sport,” “experimental,” or “provisional,” as applicable.
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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 Rotorcraft 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 airworthiness 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 petitioner supports its request with the following information:

The petitioner has provided the following information – contained in its petition and 

supplemental proprietary exhibits: 1) Altavian Nova F6500 Operator Manual, 2) Woolpert 

UAS Safety Management System, and 3) Woolpert UAS Operations Manual (hereafter

collectively referred to as the operator’s guide) – in support of its exemption request. 

The FAA has organized the petitioner’s information into four sections: 1) the unmanned 

aircraft system, 2) the UAS Pilot in Command (PIC), 3) the UAS 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 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 single propeller driven by an 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 under 14 CFR part 11 and Section 333 of the FAA Modernization and Reform Act of 

2012 (PL 112-95), subject to the following considerations:

• The safe operational history and current use of the Nova Block III UAS in the NAS;

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

• The limited areas of Woolpert’s intended operations, not in the proximity of airports or 

over populated areas;

• Conducting operations of the Nova Block III UAS pursuant to Woolpert’s Safety 

Management System;

• Conducting operations of the Nova Block III UAS within the line of sight of a 

commercial certificated pilot with a safety observer; and
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• Conducting operations in accordance with the operating limitations identified 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 their petition. In addition, the petitioner has 

integrated a variety of operating/safety restrictions into its operations as described in the 

petitioner’s operator’s guide 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 flight 

termination procedures and notify Air Traffic Control, the airspace manager, and all local 

authorities per 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 certificate 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 working with the UA will see the identification.

The petitioner states that maintenance will be performed by the Nova UAS technical lead (TL) 

and the Pilot in Charge (PIC). This includes conducting all maintenance and upkeep required 

to ensure the safe operation of the Nova Block III and authorizing use of the UA based upon 

completion of appropriate inspection(s) such as pre-flight.

UAS Pilot in Command (PIC)

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

PIC who shall hold a current commercial pilot 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 VO will initially launch 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 conditions, 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 over certain rural areas in the state of 

Ohio that are not near populated areas, airports, helipads, or state roads. Specifically, 

Woolpert’s proposed area of flight operations over the state of Ohio includes rural areas that 

are:

1. Not populated areas as depicted on VFR Sectional Aeronautical Charts;

2. Not within five (5) miles of any airport or helipad;
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3. Not within one hundred (100) meters (approximately 320 feet) of state roads having 

more than two lanes; and

4. Not within fifty (50) meters (approximately 160 feet) of state roads having two lanes

or less.

The petitioner states that all flight operations will be conducted in accordance with 

14 CFR 91.119, Minimum safe altitudes: General.

Woolpert submits that approximately 15,919 square miles, or approximately thirty-five 

percent (35%) of the total area of the state of Ohio would qualify as rural areas over which 

Woolpert could perform aerial acquisition flight operations pursuant to the requested 

exemption. 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 observer, and that the UAS 

will be limited to a maximum altitude of 400 feet AGL, and under day visual flight rules in 

visual meteorological conditions. Woolpert states in summary that it seeks to operate its Nova

Block III UAS only over rural areas of Ohio, while maintaining safe distances from any 

populated areas, airports, helipads, or roadways.

Public Interest

The petitioner states that granting their petition for exemption will further the public interest 

by allowing Woolpert to safely, efficiently, and economically perform aerial acquisition and 

research over the state of Ohio in support of government entities, agriculture, scientific 

studies, wildlife monitoring, and forestry, while also furthering the development of the state 

economy related to the oil and gas industries. Additionally, the petitioner states that use of the 

Nova Block III UAS will decrease congestion of the NAS, reduce pollution, and provide 

significant benefits to the economy. The petition further notes that the benefits of the 

proposed operation of the Nova Block III UAS will be realized without implicating any 

privacy issues.

Discussion of Public Comments:

A summary of the petition was published in the Federal Register on August 22, 2014 

(79 FR 49830).

The FAA received two comments on this petition, one favorable from the Small UAV 

Coalition and one unfavorable submitted anonymously. 

The Coalition notes that although Woolpert's proposed small UAV operations may pose no 

greater risk than small UAVs that are used by hobbyists and modelers (because of weight, 

altitude, etc.), Woolpert has proposed to abide by much stronger safety measures than are 

required for these groups. The Coalition asserts that small UAVs that operate for any purpose, 

commercial or non-commercial, should be judged based upon the precautions taken for safe 
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operation, taking into consideration the relevant technical parameters of the UAV and UAS.

The FAA has considered risk and risk mitigation in its analysis below.

The anonymous commenter identified several issues including: how pilots in manned 

airplanes will see and avoid the UA, how ATC will see the UA without a radar signature, the 

length of each UA flight, and how far the UA will travel if communications are lost.

The FAA notes that the petitioner addressed issues related to see and avoid and ATC’s 

inability to see the UA in its petition. For example, the operator’s guide describes procedures 

conducted by the PIC and the VO to see and avoid air traffic that may be operating in the 

same are. Related to Air Traffic Control awareness of operations, the petitioner will 

coordinate and establish two-way communications with the nearest Air Traffic Control 

Facility whenever during all operations. The FAA also addressed these issues within the 

conditions and limitations including: issuance of a NOTAM prior to all flights, that the UA 

must always yield the right-of-way to manned aircraft and that all operations will require a 

certification of authorization (COA) from the FAA Air Traffic Organization. Regarding 

potential loss of the communications link, the Nova Block III has design provisions to reduce 

the potential for loss of positive UA control and operational procedures in the event of such an 

occurrence.

The FAA's analysis is as follows:

Unmanned aircraft system (UAS)

The 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 49 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 Secretary 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 aircraft are typically conducted with aircraft holding 

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

modified via the supplemental type certificate (STC) process to install cameras and other 

equipment not included 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. The 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 
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accident. The 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 failures 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 maneuvers.

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” 

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

aircraft that are issued restricted certificates under 14 CFR 21.185. The petitioner’s UAS will 

not be certificated under § 21.185, 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 not necessary.

Pilot in 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 all training and currency requirements in the 

operator’s guide, prior to 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 previously 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. The operator’s guide is an acceptable equivalent to the manual materials 

referenced in 14 CFR 91.9(b)(2) and adherence to the procedures within the operator’s guide

is required through the conditions and limitations below.

The petitioner did not seek relief from 14 CFR § 91.119 Minimum safe altitudes: General. 

However, the petitioner states that it will operate the Nova Block III UA at or below 400 feet 

above ground level (AGL) and pursuant to the following self-imposed, restrictions: 

All operations will be within rural areas above the state of Ohio that are:

• Not populated areas as depicted on VFR Sectional Aeronautical Charts;

• Not within five (5) miles of any airport or helipad;
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• Not within one hundred (100) meters of state roads having more than two 

lanes; and

• Not within fifty (50) meters of state roads having two lanes or less.

The FAA has reviewed these restrictions and finds that they are not sufficient to comply with 

§ 91.119(c) which prohibits operations closer than 500 feet to any person, vessel, vehicle, or 

structure. Without a means to control or limit access to the operating areas, which could 

include roads occupied by persons and vehicles, operations must comply with § 91.119(c). In 

its exemption to Trimble Navigation (Docket No. FAA-2014-0367), Exemption No. 11110, 

the FAA found that avoidance of congested or populated areas, which are depicted in 

“yellow” on VFR charts, is a practicable step in assuring that operations are not conducted 

over congested or densely populated areas. However, using these “yellow” areas only, to 

make this determination, is not sufficient since there is no precise definition of a “congested 

area.” The FAA has stated that while there is no precise definition of a “congested area,” 

official U.S. Government aeronautical charts and NOTAMS provide general guidance for 

developing a proposed route that complies with § 91.119(c). Furthermore, aeronautical charts 

would not be expected to reflect all required local information. Pilots may obtain such 

information in a briefing from the local FSDO. This information along with the pilot’s prior 

knowledge of the area and information the pilot obtains from other sources may require an 

adjustment to the planned flight path before or during flight. Ultimately, it is the pilot’s 

responsibility to maintain the minimum safe altitudes required by § 91.119(c). See Legal 

Interpretation to Melvin O. Cintron, from Rebecca B. MacPherson (Aug. 28, 2012).

Therefore, operations within “yellow” areas as shown on World Aeronautical Charts (WAC), 

Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC) are prohibited. In 

addition, operations over congested or densely populated areas other than those depicted in 

“yellow” are also prohibited as stated in the conditions and limitations below.

All nonparticipating persons, vessels, vehicles, and structures will be required to be at least 

500 feet from flight operations. 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 these 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 conducted so close 

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 adherence to the 

procedures in the operator’s guide and the FAA’s additional conditions and limitations 

outlined below.

Additionally, in evaluating the petitioner’s proposed operating parameters with regard to 

VLOS and a safe operating perimeter, the FAA considered operations from a moving device 
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or vehicle. Since the petitioner did not discuss provisions for these circumstances, the 

conditions and limitations below prohibit operations from moving devices or vehicles.

Regarding an Air Traffic Organization (ATO)-issued Certificate of Waiver or Authorization 

(COA), Section 333, in pertinent part, states 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 Air Traffic 

Control (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 are unique to UAS operations. The COA will require the operator to 

request a Notice to Airman (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 their 

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

enabled by this exemption is in the public interest. The proposed operations will provide 

benefits to agriculture, science, the environment, wildlife monitoring, forestry, and energy.

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

petitioner:

Relief sought by petitioner (14 CFR) FAA determination (14 CFR)

Part 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 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, Woolpert, Inc. (Woolpert) is granted an exemption 

from 14 CFR § 91.119(c) to 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.
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Conditions and Limitations

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

The Woolpert UAS Safety Management System, the Woolpert UAS Operations Manual, and 

the Altavian Nova F6500 Operator Manual are hereafter collectively referred to as the 

operator’s guide.

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 following aircraft 

described in the operator’s guide which is a fixed-wing aircraft weighing less than 15

pounds: Woolpert Altavian Nova Block III (Nova Block III). Proposed operations of 

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

2) The Nova Block III UA may not be flown at an indicated airspeed exceeding 58

knots.

3) The Nova Block III UA must be operated at an altitude of no more than 400 feet 

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

4) The Nova Block III UA must be operated within visual line of sight (VLOS) of the 

Pilot in Charge/Command (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.

5) All operations must utilize a Visual Observer/Observer (VO). 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. 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 prescribed 

in the operator’s guide.

6) The operator’s guide 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 procedures outlined in the 

operator’s guide, the conditions and limitations herein take precedence and must be 

followed. Otherwise, the operator must follow the procedures as outlined in its 

operator’s guide.

The operator may update or revise its operator’s guide. It is the operator’s 

responsibility to track such revisions and present updated and revised documents to 

the Administrator upon request. The operator must also present updated and revised 
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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 amendment to their 

grant of exemption. The FAA’s UAS Integration Office (AFS-80) may be contacted if 

questions arise regarding updates or revisions to the operator’s guide.

7) Prior to each flight the PIC must inspect the Nova Block III UAS to ensure it is in a 

condition for safe flight. If the inspection reveals a condition that affects the safe 

operation of the Nova Block III UAS, the Nova Block III UA is prohibited from 

operating until the necessary maintenance has been performed and the Nova Block III 

UAS is found to be in a condition for safe flight. The Nova Block III Ground Control 

Station must be included in the preflight inspection. All maintenance and alterations 

must be properly documented in the aircraft records.

8) Any Nova 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 Nova Block III UA aircraft record of the flight. 

9) In addition to the pre-flight inspection section in the operator’s guide, the preflight 

inspection must also account for all discrepancies, i.e. inoperable components, items, 

or equipment, not already covered in the relevant sections of the operator’s guide.

10) The operator must follow the Nova Block III manufacturer’s UAS 

aircraft/component, maintenance, overhaul, replacement, inspection, and life limit

requirements. 

11) Woolpert must carry out their maintenance, inspections, and record keeping 

requirements, in accordance with the operator’s guide. 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 Nova Block III

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

12) Woolpert Nova 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) Nova Block III Technical Lead, PIC, and VO, must receive and document training

referenced in the operator’s guide.

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

and Safety Bulletins.
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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, the PIC and VO must have successfully completed 

Woolpert’s training syllabus as outlined in the operator’s guide. In addition, the PIC 

and VO must also have successfully completed annual (recurrent) training in 

accordance with the operator’s guide. A record of training must be documented and 

made available upon request by the Administrator. Prior documented flight 

experience that was obtained in compliance with applicable regulations may satisfy 

this requirement. Training, proficiency, and experience-building flights can also be 

conducted under this grant of exemption to accomplish the required flights and flight 

time.

17) If the Nova 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 operator’s guide.

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

accordance with the operator’s guide.

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 Nova 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 radio frequency spectrum used for operation and 

control of the Nova 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 Nova 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 Nova Block III UA must remain clear and yield the right of way to all other 

aircraft operations and activities at all times.
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24) The Nova Block III UAS may not be operated from any moving device or vehicle. 

25) Nova Block III UAS operations may not be conducted during night, as defined in 

14 CFR 1.1.

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

The Nova Block III 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.

27) The Nova Block III UA may not operate within 5 nautical miles of the geographic 

center of an airport as denoted on a current FAA-published aeronautical chart.

28) The Nova Block III UA may not be operated over congested or densely populated 

areas. These areas include but are not limited to the yellow areas depicted on World 

Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal 

Area Charts (TAC). However, aeronautical charts may not reflect pertinent local 

information. Ultimately, it is the PIC’s responsibility to maintain the minimum safe 

altitudes required by § 91.119.

29) Operation of the Nova Block III UA must be conducted at least 500 feet from all

persons, vessels, vehicles, and structures not directly involved in the operation. 

30) 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 operations. Operations closer than 500 feet 

from the PIC, VO, operator trainees and essential persons, are permitted when 

operationally necessary; but never so close to present an undue hazard, per 

§ 91.119(a).

31) 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.

32) All operations 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.

33) 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 must be reported to the National Transportation 
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Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

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

pilot in charge/command (PIC), and operator 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, 2016, unless sooner superseded or rescinded.

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

/s/

John S. Duncan

Director, Flight Standards Service