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PIEDMONT VIRGINIA COMMUNITYCOLLEGE Piedmont Virginia Community Cotlege 501 College Dr. Charlottesville, VA 22902 February 5, 2016 U. S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590 501 College Drive Charlottesville, Virginia 22902-7589 434-961-3900 4334-961-5200 V/TIY434-977-4265 www.pvcc.edu

RE: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 oftheFederal Aviation Regulations from 14 C.P.R. 45.23(b); 14 CFRPart21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151(a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b). Dear Sir orMadam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.P.R. Part 11, PIEDMONT VIRGINIA COMMUNITY COLLEGE ("the applicant"), operator of Small Unmanned Aircraft Systems ("sUASs") equipped to conduct sUAS flight training, hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its sUASs, so long as such operations are conducted within and under the conditions outlined herein or as may be establishedbythe FAA as required by Section 333. As described more fully below, the requested exemption would permit the operation of small, unmanned, and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited, 2) predetermined, 3) controlled as to access, and 4) would provide safety enhancements to the already safe operations in emergency services, public safety, and commercial operations or aerial data collection and remote sensing presently using conventional aircraft. Approval ofthis exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) responsibilities to"

...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Section 333(c) ofthe Reform Act. The name and address ofthe applicant is: PIEDMONT VIRGINIA COMMUNITY COLLEGE Attn: Frank Friedman Ph: 434.961.5200 Email: ffriedman @pvcc.eduPIEDMONT VIRGINIA COMMUNITYCOLLEGE Address: 501 College Dr. Charlottesville, VA 22902 Regulations from which the exemption is requested: 14 CFR Part 21 14 C.F.R. 45.23(b) 14 CFR 61.113 (a) & (b) 14 C.F.R. 91.7 (a) 14 CFR 91.9 (b) (2) 14 C.F.R. 91.103 14 C.F.R. 91.109 14 C.F. R. 91.119 14 C.F.R. 91.121 14 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR407 (a) (1) 14 CFR 409 (a) (2) 14 CFR417 (a) & (b) This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) ofthe Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in thenational airspace system (NAS) before completion oftherulemaking required under Section 332 ofthe Reform Act. In making this determination, the Secretary is required to determine which types ofUASs do not create ahazardto users ofthe NAS orthe public or pose athreat to national security in light ofthe following:

• The UAS's size, weight, speed, and operational capability; • Operation ofthe UAS in closeproximityto airports and populated areas; and • Operation ofthe UAS within visual line ofsight ofthe operator. Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." Id. §333(c) (emphasis added). 1

1Applicant interprets this provision to place the duty on the Administratorto not onlyprocess applications for exemptions under section 333, butfor the Administratorto craft conditions for the safe operation ofthe UAS, ifit shouldbe determined that the conditions set forth herein do not fulfill the statutoryrequirements for approval. 

### 2PIEDMONT VIRGINIA COMMUNITY COLLEGE The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authoritybyits terms includes exemptingcivil aircraft, as thetermis defined under §40101 ofthe Act, which includes sUASs, fromtherequirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) ofthis section or any sections 44702-44716 ofthis title ifthe Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1). Theapplicant's sUAS (Appendix 1) arefixed wing androtorcraft, weighing 55 orfewer lbs. including payload. They operate under normal conditions at a speed ofno more than 25 to 35 knots and have the capability to hover and move in the vertical and horizontal plane simultaneously and move in the horizontal plane. They will operate only in line of sight and will operate only within the sterile area described in the Unmanned Aircraft Systems Operations Manual(s), attached as Appendix 2 (hereinafter "theManuals"). Such operations insure that the sUAS does "not create a hazard to users ofthe national airspace system orthe public."2 Given the small size of the sUASs involved and the restricted sterile environment within which they will operate, the applicant falls squarely within that zone of safety (an equivalentlevel ofsafety) in which Congress envisionedthattheFAAmust, byexemption, allow commercial operations ofUASs to commence immediately. Also due to the size of the UASs and the restricted areas in which the relevant sUASs will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 ofthe Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing UASs for training of emergency services, public safety personnel and commercial operators for aerial data collection and remote sensing, the granting oftherequested exemptions is inthe public interest. Accordingly, the applicant respectfullyrequests that theFAA grant therequested exemption without delay. Background Information The applicant is in the business of training emergency services, public safety and commercial operators for aerial data collection and remote sensing. The applicant's clients look to the applicant for safe operations of sUAS. The applicant has developed specific safeUAV operationalprocedures. Increasingly, the applicanthas clients lookingfor sUAS services for aerial data collection and remote sensing.

2 ReformAct Section 333 (b). 

### 3PIEDMONT VIRGINIA COMMUNITY COLLEGE Operations performed bythe applicant include: 1. Training ofemergency services sUAS operators for aerial datacollection andremote sensing. 2. Training of public safety s UAS operators for aerial data collection and remote sensing. 3. Training of commercial sUAS operators for aerial data collection and remote sensing.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY The applicant proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate within the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the already safe aerial data collection and remote sensing conducted with conventional aircraft. These limitations and conditions to which the applicant agrees to be bound when conducting commercial operations under an FAA issued exemption include: 1. The sUAS will weigh less than 55lbs. 2. Flights will be operated within line ofsight ofa pilot and/or observer. 3. Maximum total flight time for each operational flight will be 30 minutes. Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. 4. Flights will be operated at an altitude ofno more than 400 feet AGL or, not more than 200 feet above an elevatedplatformfrom which flight is planned. 5. Minimum crew for each operation will consist ofthe sUAS Pilot and the Visual Observer. 6. The sUAS pilot-in-command (PIC) will hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will 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 7. If a pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualifications, is also present on site, thatperson can also bedesignated as PIC. 8. The sUAS will only operate within defined boundaries as outlined in Section 8.4 ofthe Manual. 9. Abriefing willbeconductedinregardto theplanned sUAS operations priorto each mission. It will be mandatory that all personnel who will be performing duties within the boundaries ofthe safetyperimeterbepresent for this briefing. 4PIEDMONT VIRGINIA COMMUNITYCOLLEGE 10. The operatorwill file aFAAForm7711-1, orits equivalent, as modified in light of the requested exemption, with the appropriate Flight Standards District Office (FSDO). 11. The operator will obtain the consent of all persons involved in the mission and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, and this radius maybe reducedto 30feet basedupon an equivalent level of safety determination, as required by Section 8.4 of the Manual. With the advanced permission of the relevant FSDO, operations at closer range can be approved. 12. The operatorwill submit awritten Plan ofActivities to theFSDO three days before theproposed mission as required in Section 8.1 ofthe Manual. Items will include: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS mission conducted under this petition ofexemption; c. Make, model, and serial orN-number ofUAS to beused; d. Name and certificate number ofUAS PICs involved in the mission; e. A statementthattheoperatorhas obtainedpermissionfrompropertyowners and/or local officials to conduct the mission; f. Thelist ofthose who gave permission made available to the inspector upon request; g. Signature ofexemption-holder orrepresentative; and h. A description ofthe flight activity, including maps or diagrams ofany area, city, town, county, and/or state over which the mission will be conducted and the altitudes essential to accomplish the operation. 13. Pilot and observer will have been trained in operation of UAS generally and received up-to-date information on the particular UAS to be operated as required in Sections 7.4 and 7.5 ofthe Manual. 14. Observer and pilot will at all times be able to communicatebyvoice. 15. Written and/or oralpermission from therelevantpropertyholders willbe obtained. 16. All requiredpermissions and permits willbe obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 17. Ifthe sUAS loses communications or loses its GPS signal, the UAS will have the capability to return to a pre-determined location within the SecurityPerimeter and land. 18. The sUAS willhavethe capabilityto abort aflight in case ofunpredicted obstacles oremergencies. 14 C.F.R. Part 21, SubpartH: Airworthiness Certificates 14 C.F.R. §91.203 (a) (1) Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as requiredbyFAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by 

### 5PIEDMONT VIRGINIA COMMUNITYCOLLEGE the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 oftheReform Actboth authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without therestrictions and conditions proposed. The sUAS to be operated hereunderis less than 55 lbs. fully loaded, carries neither apilotnorpassenger, carries no explosivematerials orflammable liquidfuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and observer, pursuantto theManual'spolicies, andunder and in compliancewith local public safety requirements, to provide security for the area of operation as is now done with conventional manned rotorcraft and/or fixed wing aircraft. The FAA will have advance notice ofall operations. These safety enhancements, which already apply to civil aircraft operated in connection with emergency, public safety and commercial aerial data collection and remote sensing, provide a greater degree ofsafetyto thepublic and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.P.R. Part 21, SubpartH. Lastly, application ofthese same criteriademonstrates thatthere is no credible threatto national security posedbythe UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials or flammable liquid fuels, and inability to carry a substantial external load. 14 C.F.R. § 45.23 (b). Marking ofthe Aircraft The regulation requires: When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport," "experimental," or "provisional," as applicable. Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to a cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the size ofthe sUAV, two-inch lettering will

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PIEDMONT VIRGINIA COMMUNITYCOLLEGE beimpossible. Theword "Experimental" willbeplacedonthefuselage in compliancewith §45.29 (f). The equivalent level of safety will beprovidedbyhaving the sUAV marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAV will see the identification ofthe UAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A. 14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command. Sections 61.113 (a) & (b) limit private pilots to non-commercial operations. BecausetheUAS will notcarry apilot orpassengers, theproposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a pilot's certificate operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area ofoperation is controlled and restricted, and all flights are planned and coordinated in advance as set forth in the Manual. The level of safety provided by the requirements included in the Manual exceeds that provided by a single individual holding a commercialpilot's certificate operating a conventional aircraft. Therisks associatedwith the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requestedby apilot's certificate as the PIC exceeds thepresentlevel ofsafety achieved by 14 C.P.R. §61.113 (a) & (b). 14 C.F.R. §91.7(a): Civil aircraft airworthiness. The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size ofthe aircraft and therequirements contained in theManual for maintenance and use ofsafetychecklists priorto each flight, as set forth in Sections 9.1 and 9.6, an equivalent level of safety will beprovided. 14 C.F.R. § 91.9 (b) (2): Civil AircraftFlight Manual in the Aircraft. Section 91.9 (b) (2) provides: No person may operate a U.S.-registered civil aircraft

... (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane

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or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not onlybecausethere is no pilot on board, butbecause there is no room orcapacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground control point where thepilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700. 14 C.F.R. § 91.103: Preflight action This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft, an exemption will be needed. An equivalent level of safety will be provided as set forth in Sections 8 and 9 ofthe Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances, and aircraft performance databefore initiation offlight. 14 C.F.R. §91.109: Flightinstruction Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training withoutfully functional dualcontrols for anumberofaircraft and for flight instruction in experimental aircraft. See Exemption Nos. 5778K & 9862A. The equivalent level ofsafety provided bythe fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft. 14 C.F.R. §91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119(d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevatedplatformfrom which operation is planned, an exemption maybeneeded 8

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PIEDMONT VIRGINIA COMMUNITYCOLLEGE to allow such operations. As set forth herein, except for the limited conditions statedin the Manual, the UAS will never operate athigherthan 400 AGL. Itwill, however, be operated in a restricted area with a security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent. The equivalent level ofsafetywill be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner or local officials. Because ofthe advance notice to the property owner and participants in the mission, all affectedindividuals willbeaware ofthe planned flight operations as set forth in Section 6.2, 8.1, and 8.2 oftheManual. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum55lbs. proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL by emergency, public safety and commercial aerial data collection and remote sensing. In addition, the low-altitude operations of the sUAS will ensure separation between these small UAS operations and the operations ofconventional aircraft that must comply with Section 91.119. 14 C.F.R. §91.121 Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

...to the elevation ofthe departure airport or an appropriate altimeter setting availablebefore departure." As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved bythe operator, pursuantto theManual and safety checklist, confirming the altitude of the launch site shown on the GPS altitude indicator before flight. 14 C.F.R. § 91.151(a): Fuel Requirements for Flightin VFR Conditions Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed- (1) During the day, to fly after that for at least 30 minutes; or (2) at night, to fly after that for at least45 minutes." The battery powering the sUAS provides approximately 30 minutes of powered flight. To meetthe 30-minutereserverequirement in 14 CFR §91.151, sUAS flights would be limited to approximately 20 minutes in length. Given the limitations on the UAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

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PIEDMONT VIRGINIA COMMUNITYCOLLEGE Applicant believes that an exemption from 14 CFR §91.151(a) falls within the scope ofprior exemptions. See Exemption 10673 (allowing LockheedMartin Corporation to operatewithoutcompliance with FAR91.151 (a)). Operatingthe smallUAS, in atightly controlled area whereonlypeople and property owners orofficialrepresentatives whohave signedwaivers willbe allowed, withless than 30 minutes ofreservefuel, does notengender the type ofrisks that Section 91.151(a) was intended to alleviate given the size and speed ofthe small UAS. Additionally, limiting sUAS flights to 20 minutes would greatly reduce the utilityfor which the exemption will begranted. Applicant believes that an equivalent level of safety can be achieved by limiting flights to 20 minutes or 25% of battery power whichever happens first. This restriction wouldbemorethan adequatetoreturnthe s UAS to its plannedlandingzonefrom anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808. 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within itthefollowing: (1) An appropriate and current airworthiness certificate

.... (b) Nopersonmayoperate acivil aircraftunless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers orcrew. The UAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them onthe sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565,9665,9789, 9789A, 9797, 9797A, 9816A, and 10700. 14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections


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PIEDMONT VIRGINIA COMMUNITYCOLLEGE Theseregulations require that an aircraft operator or owner "shallhave that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 ofthis chapter.

..," and others shall inspect or maintain the aircraft in compliance with Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections willnotapplyto the applicant. Maintenancewillbeaccomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Manual (See Sections 8.6 and 9). An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise the UAS can land immediately and will be operating from no higher than 400 feet AGL. As provided in the Manual, the operator will ensurethatthe UAS is in working orderprior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

Pursuant to 14 C.P.R. Part 11, the following summary is provided for publication in the Federal Register, should itbe determined that publication is needed: Applicant seeks an exemption from the following rules: 14 C.P.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.P.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in motion picture and television operations. Approval ofexemptions allowing commercial operations of sUASs in aerial data collection and remote sensing will enhance safety by reducing risk. Conventional aerial data collection and remote sensing, usingjetorpiston power aircraft, operate at extremely low altitudesjust feet from the infrastructure being inspected and in extreme proximity to people and structures; and present the risks associated with vehicles that weigh in the neighborhood of4,000lbs, carryinglarge amounts of jetA orotherfuel. Such aircraft must fly to and from the work location. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried on board. The sUAS is carried to the worksite and not flown. The sUAS will carryno passengers orcrew and, therefore, will not exposethemto therisks associated with manned aircraft flights.



### 11PIEDMONT VIRGINIA COMMUNITYCOLLEGE The operation of small UASs, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level ofsafety supporting the grant of the exemptions requested herein, including exempting the applicant from the requirements ofPart 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximityto the ground and people. Privacy All flights will occur overprivate or controlled access property withthe property owner's prior consent and knowledge. remote sensing services. public will beperformed for people who have also consented for work to be performed or otherwise have agreed to be in the area where UAS flight will take place. Conclusion Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of 2012

- size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

- provide more than adequate justification for the grant ofthe requested exemptions allowing commercial operation of applicant's UAS for training of emergency services, public safety and commercial operations for aerial data collection and remote sensing pursuant to the Manual appended hereto. Sincerely,



### Frank Friedrnan, President Piedmont Virginia Community College



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Appendix 1 

### 1.1

- DJIPhantom Inspire 1

1.2

- DJI Phantom 3 Pro

1.3

- Action Drone AD1



### 13PIEDMONT VIRGINIA COMMUNITYCOLLEGE



### 1.4

- ProDroneByrd

1.5

- UAV Solutions Phoenix ACELEPro

1.5

- HoneyComb AgDrone



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### 1.6

- PrecisionhawkLancaster

1.7- Aerialtronics Zenith



### 15PIEDMONT VIRGINIA COMMUNITYCOLLEGE 

### 1.8

- Pulse Aerospace Vapor55



### 1.8- C-Astral Bramor



### 1.9

- UAVFactory PenguinBE



### 16PIEDMONT VIRGINIA COMMUNITYCOLLEGE

Appendix 2 Please see the attached: sUAS Operating Manual sUAS Pre-Flight Safety Checklist



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# Unmanned Aircraft System Operations Manual PIEDMONT VIRGINIA COMMUNITY COLLEGE

### UnmannedAircraft Systems Operations Manual
9.7 OTHER

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### UnmannedAircraft Systems Operations Manual operations with the need to accomplish the mission while maintaining public privacy and the freedom from intrusion.



### 4. Definitions 1. Aircraft: any contrivance invented, used, or designed to navigate, or fly in, the air. 2. Airport: a landing area used regularly by aircraft for receiving or discharging passengers or cargo. 3. Civil aircraft: an aircraft except apublic aircraft. 4. Landing area: aplace on land or water, including an airport orintermediatelanding field, used, orintendedto beused, forthetakeoffandlanding ofaircraft, evenwhen facilities are not provided for sheltering, servicing, or repairing aircraft, or for receiving or discharging passengers orcargo. 

### 5. Administration 5.1 Operations Manual 1. The policies and procedures contained in this manual are issued by PIEDMONT VIRGINIA COMMUNITY COLLEGE. As such itis an officialbusiness document ofPIEDMONT VIRGINIA COMMUNITY COLLEGE. 2. This manual is not intended to be all-inclusive, but as a supplement to other companyguidelines, FederalAviationAdministrationregulations, pre-flight safety checklists, aircraft manufacturers' approved flight manual, etc. 3. This manual is written to address UAS operations as they existed when it was drafted. Equipment, personnel, environment (internal and external), etc., change over time. The management of change involves a systematic approach to monitoring organizational change and is a critical part of the risk management process. Given this, it is essential that this manual be continually updated as necessary. The entire manual must be reviewed, at a minimum, annually to assure it is up to date. Any changes to the manual will be communicated as currently dictated bycompany policy. 4. A copy of the manual (electronic and/or paper) is issued to every person having UAS responsibilities. 5.2 Organization 1. The UAS unit is comprised of those personnel approved by PIEDMONT VIRGINIA COMMUNITY COLLEGE and includes operators, observers and others deemed necessary and have assignment as part ofthe UAS crew. 2. Assignment to the UAS crew is carefully selected by PIEDMONT VIRGINIA COMMUNITY COLLEGE from specially trained staffmembers ofPIEDMONT VIRGINIA COMMUNITY COLLEGE with knowledge of the airspace within

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b. An observer's primary duty is to operate the UAS's equipment including cameras, FLIR, radio communications with other crew members and property owners as well as be an observer for anything that may affect the operator's primary duty (see and avoid). c. The UAS Coordinator maintains a file for each observer, which includes copies oftraining records, UAS incidents, etc.

5.4 Facilities 1. UAS operations are housed and maintained at afacility designatedbyPIEDMONT VIRGINIA COMMUNITY COLLEGE. 2. Personnel must not leave the designated facility without making sure the UAS equipment is secured. 3. All personnel are equally responsible for maintaining the facility in a neat, clean and orderly fashion. 5.5 Scheduling 1. To facilitate thebroad use ofthe UAS, it shall be made available to all UAS flight crew members. 2. To maintain a level ofproficiency with the UAS, operators are required, as part of their acceptance into the UAS flight crew, to attend training every two months. Training is coordinatedthrough the UAS flight crew and announced in advance for scheduling purposes. 5.6 Miscellaneous 1. Inquiries from the news media must be forwarded to the PIEDMONT VIRGINIA COMMUNITY COLLEGE information officer, or college president. Operators/Observers shall follow currently established company policy regarding interactions and inquiries from the media. 2. Requests for support from third-parties will be responded to by the UAS coordinator. Shouldtherequest involve an immediatethreatto life, orproperty, the operatoris authorizedto accept ordeclinetherequest. Properpolicy andprocedure, as well as FAA regulations must be followed when accepting mutual aid support for the UAS. 3. Complaints or inquiries regarding UAS operations must be referred to the UAS coordinator. 

### 6. Safety 6.1 Safety Policy

4UnmannedAircraft Systems Operations Manual

6.3 Safety Officer · Operator/Observer/Coordinator 1. In regards to safety, all members of the UAS flight crew are responsible for the following: a. Ensuring all flight operations personnel understand applicable regulatory requirements, standards and organizational safety policies and procedures. b. Observe and control safety systems bymonitoring all operations. c. Review standards and the practices ofcompany personnel as they impact operational safety. d. Communicate all reported safetyrelated problems andthe corrective action taken. If there were any in-flight problems (or learned experiences), the proper procedures for handling that problem shouldbediscussed. e. Copy and circulatepertinent safety information. f. Copy and circulate emergency safetybulletins. g. Place any electronic copies of safety information or bulletins in a conspicuous location for all employees to access. h. Itis emphasized again that safety is the responsibility ofALL members of the UAS unit. 6.4 Safety Training 1. All members shall receive training in the following subjects prior to operating the UAS: a. Company commitmentto safety b. Company policy c. UAS member's role in safety d. Emergency safety procedures 2. All members shall review the company safety policy and procedures on an annual basis and that review shall be noted in their training history. 6.5 Medical Factors 1. Operator and Observers shall only deploy the UAS when rested and emotionally prepared for the tasks at hand. 2. Physical illness, exhaustion, emotional problems, etc., seriously impairjudgment, memory and alertness. The safest rule is not to act as an operator or observer when sufferingfrom anyofthe above. Members areexpectedto "standdown" whenthese problems could reasonably be expected to affect their ability to perform flight duties. 3. A self-assessment ofphysical condition shall be made by all members during preflight activities. 4. Performance can be seriously hampered by prescription and over-the-counter drugs. The UAS Coordinator must be advised anytime such drugs are being taken. If it is determined that the medication being taken could hamper an operator or observer, that member shall beprohibited from the deployment or exercise.



### 6UnmannedAircraft Systems Operations Manual
2. In conjunctionwith fulfilling alltrainingrequirements for operator/observerduties, the new member must also become familiar with UAS operations, the aircraft and its equipment. 3. Any new member who fails to successfully complete the initial training may be denied as a member ofthe UAS flight crew. 4. Before a member can fly as an operator, they must complete at least 8 hours of flight training with the UAS instructors to show proficiency ofthe flight training exercises and the airframe. This must be accomplished to show their ability and knowledge ofthe UAS. 7.5 Recurrent Training 1. All members within the unit shall maintain proficiency in their operator/observer abilities. Members who do not have any documented training orflight time within a span of90 days will have to show proficiencybefore being an operator/observer during a deployment or exercise. 2. Recurrent training is not limited to actual operating/observer skills but includes knowledge ofall pertinent VAS/aviation matters. 3. Failureto prove proficiency can result in removal from UAS responsibilities. 7.6 Miscellaneous 1. Depending on the nature of the training request, all efforts are made to accommodate the hours oftraining so as little impact is made to staffing levels. 2. Allrequests for training shallbeapprovedthrough themember's chain ofcommand and timekeeping during thosetraining hours are markedbythe UAS coordinator. 3. Members are encouraged to attend, and forward information on FAA sponsored safety seminars. 4. Training shall only be conducted at approved locations and follow the provisions within the approved FAAregulations. 

### 8. General OperatingProcedures 8.1 Requestfor UAS Support 1. Requests for UAS support shallbemade through the UAS coordinatorwho has the most current list ofUAS operators and observers to contact. 2. Requests for UAS support can be made at any time during the day ornight. 3. The UAS coordinator will submit a written Plan of Activities to the local FAA FSDO three days before the proposed mission. 4. If a request is made for UAS support during the night, PIEDMONT VIRGINIA COMMUNITY COLLEGE must contactthe local FAA FSDO for approval. 8.2 Call-outProcedure 1. The UAS coordinator will screen all initial requests to use aUAS.



### 8UnmannedAircraft Systems Operations Manual

1. The UAS shall not beused for the purpose ofrandom surveillance. 2. Ifseveral separaterequests for UAS support arereceived simultaneously, they shall beprioritized. 8.4 FlightBoundaries 1. Although there may be requests for UAS support in restricted airspace, FAA regulations for UAS restrict UAS deployment inside restricted airspace. 2. At no time shall UAS support be granted inside restricted airspace without first obtaining permission from the local FAA FSDO and approval bylocal authorities. 3. Maximum altitude shall not be set more than 400 feet per the FAA regulatory standards. 4. The operator will obtain the consent of all persons involved in the mission and ensure that only consenting persons will be allowed within 100 feet ofthe flight operation, and this radius maybereduced to 30feet basedupon an equivalent level ofsafety determination. 8.5 Minimum Personnel Requirements 1. Dueto thenatureofthemission, theminimumpersonnelrequired on ALLmissions will be an operator and observer. Under no circumstances will an operator attempt to complete a deployment alone. 2. Although training is not considered a mission, an observer shall be used. 8.6 Personnel Responsibilities for Deployments OPEN COMMUNICATION ACHIEVES SAFE OPERATIONS 1. Operator a. The operator is directly responsible for, and is the final authority over the actual operation ofthe UAS. b. Operatorshave absolute authorityto reject aflightbased onpersonnel safety or violation of FAA regulations. No member of PIEDMONT VIRGINIA COMMUNITY COLLEGE, regardless of status, shall order an operator to make a flight when, in the opinion of the operator, it poses a risk to personnel oris in violation ofFAA regulations. c. Operators areresponsiblefor compliancewiththis manual, companypolicy and procedure and FAA regulations. d. The operator's main duty during the deployment ofthe UAS is to operate theUAS safelywhile accomplishing the goals ofthe deployment. e. Operators shall see-and-avoid any obstaclethatwill lessen safety duringthe mission. f. Operators shall be responsive to the requests of the observer in order to accomplish the deployment.



### 10UnmannedAircraft Systems Operations Manual
5. Anyphysical equipmentthat cannotberesolved on-site, and which have an impact on safetyorthemission, will overridethedeployment. Theseissues willberesolved before flight. 9.2 Weather 1. Before each deployment the operator/observer will ensure that he/she gathers enoughinformationto makethemselves familiar withtheweather situationexisting throughout the area of deployment. The operator shall utilize FAA approved weather resources to obtain the latest and most current weather conditions. 2. An anemometer should be utilized in order to better estimate the wind speed and determine ifit is within the capabilities ofthe airframebeing flown. 3. Operators/Observers should use the Beaufort Scale when making deployment decisions in regards to wind conditions. 4. The weatherconditions reportedfor the operation shallberecordedin thepre-flight checklist. 5. The operator shall ensure that the flight will occur within FAA VFR weather requirements. 9.3 Documentation 1. Inspection and weather will be documented priorto flight within the log book. 2. After each flight, the operator will complete a statement documenting the UAS operations. 9.4 Planning 1. The operator/observer shall familiarize themselves with all available information concerning the deployment including, but not limited to, the weather conditions, hazards, description ofthe incident, deployment goals, etc. 2. Operators will ensure that the location for take-off and emergency landing is adequate for a safe deployment. a. The take-off/landing area should be clearly marked and identifiable with short cones. b. At least one emergency landing area should beidentified per deployment. 3. Operators will ensure that they are aware oftheir surroundings in the event that an emergency landing is necessary. This includes the ability to recover the UAS.

9.5 Checklists 1. Operators shall utilize pre-flight checklists to ensure the highest level ofsafety for deployment. 2. Prior to flight, the flight log shall be initiated.



### 12

### PRE-FLIGHT CHECKLIST* HULL AND PROPELLORS DIAnhull screws are securely fastened to the body ofthe UAS. DIAnpropellers are securely fastened to the motors. 

# D tfransmitters and accompanying wires are securely fastened to the hull. 01¢amera(s), gimbal(s), and accompanying wires are securely fastened to the hull. Dtfhereare no loose parts, wires, screws, orextremities that can fall from the UAS. !operatorsNotes: SAFETY CHECK 

# D [heoperator performed avisual review ofthe area ofoperation. DITheoperator is aware ofaerial obstructions (i.e., poles, structures, utility wires, trees). D !The operator is not within 3-miles ofan airport. D [he operator clearly marked atake-off/landing zone with 4 orange caution cones. 

# D !The operatorhas clearly announced that aUAS is preparing for flight. D jThe operator has ensured no persons or animals are near the caution zone. Dlweatherpermits the safe operation oftheUAS (i.e., little to no wind, no precipitation, D**~f**working in pairs, the second operatorhas a pair ofbinoculars to maintain line ofsight

## I !operatorsNotes: I POWER TO SYSTEM j[ 

### j !The batterybeing R!ac.ed into the U-f..S )las a

### f~_acizy~ . .

# Jll

1

# [J**~e** batteries inside the RC

### co~troller have a sufficient

### ch~ 

# =:=J. lr-:=JIThe£eis a

### spar~ UAS battery with a full charge.

. .

### :~- 

# Jl 10**~-are** spare batteries for the RC controller with afull charge. 

# ===-=:Jj**j[]fu~_UAS** battery is securely fastened within the UAS hull

. - 

# =:]I I LJ[The UAS powers up completely indicating a normal audible**chime~pera~iMty**.. 

# ==:J 1 

# il

___j!Ailljghts**~?the** UAS are operating normally.

. 

# Ji**~~~Notes:** 

## -=---ll RC/WIFI/FPV CONNECTIVITY 

# D !There is a steady connectionbetweenthe RC controller and the UAS. D !There is a steady connectionbetweenthe video transmitter and the FPV receiver. D tfhe UAS is responding accurately and efficientlyto RC commands. DIVideoequipment is responding accurately and efficientlyto FPV·commands. D WPv OSD is operational. DIReController is setto GPS and HL and CL modes are both turned of£ !operatorsNotes:

UAS Operator's Signature:

__________ _ Date:

_______ _ 

### *All UAS Operators must perform this pre-flight checklist prior to every respective flight.