1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us



## Exemption 333 Re quest for UAS Operation s utilizing

Aerial Release for Sterile Insect Technique (SIT)

Executive Summary The M3 Consulting Group Sterile Insect technique ( SIT ) program is designed to offer researchers and public/private organizations a tool to enhance and/or supplement their existing SIT operations. Historical SIT operations have been co mmissioned using ground release and

manned aviation release methods. The M3 Co nsulting Group SIT program is designed to dramatically increase the quality and effectiveness of aerial SIT release at a potentially discounted price point. This will be achieved by utilizing cost effective Unmanned Aircraft Systems (UAS) to release substr ate at lower altitudes and airspeeds.

Operational Summary The M3 Consulting Group survey program will operate at low altitudes and slow airspeeds to perform SIT. Anticipated release height will be no more than 200 feet AGL and anticipated

release speeds will be under 30 KTAS in airspeed. Operations will be restricted to class G airspace , occur only during daylight hours in VMC conditions , and us e Class E visibility and

weather standards as stated in 14 CFR 91.155.

Operations will require an obser ver working in tandem with the Pilot in Command ( PIC ) of the aircraft to comply with established See and Avoid methods regarding UAS operations in the NAS. Operations will be conducted wit hin 1⁄2 NM laterally and below 200 feet AGL. D aily operations

, multi ple times per week , are anticipated

.

Benefit to the Public The M3 Consulting Group SIT Program will benefit the public by providing a safe, cost effective and rapid response means to provide release of SIT insects

. An additional factor will be the elimination of risk to agricultural pilots as t he aerial release of any substrate req uires low and slow flight to ensure precision, which is extremely dangerous maneuver for conventional

manned aircraft

. Aircraft Type

M3 Co nsulting Group intends to use multiple types of aircraft for its SIT release program. F light

vehicles will consist of a Vertical Take

- O ff and Land (VTOL) design and two fixed wing design s . T hese airframes will be operated in the same manner and will have s imilar Standard Operational Procedures (SOP) associated with them.

M3 Consulting Group Hummingbird UAS (Manufactured by M3 Consulting Group) See attached UAS Operating Manual1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

M3 Consulting Group SOLO UAS (Manufactured by 3D Robotics) See attached UAS Oper ating Manual

M3 Consulting Group Desert Cardinal UAS (Manufactured by M3 Consulting Group) See attached UAS Operating Manual

Operational Risk Mitigation M3 Consulting Group currently operates UAS utilizing SIT professionally under COA 2014

- WSA

- 225. The M3 Consulting Group SIT program will operate in exactly the same manner. Listed below is the order of operations that the M3 Consulting Group survey program will

utilize:

1. PIC Completes Daily Flight Survey

2. PIC files any Notams or disclosu res required for flight operations

3. PIC Completes Daily Risk assessment

4. PIC Completes Pre Flight Brief to crew

a. Assigns duties

b. Assigns duty locations

c. Gives description of operation to crew

i. Brief contents of COA

ii. Altitudes to be Flown

iii. Mission Overview

iv. Frequenc ies to be used

v. Flight time including reserve requirements

vi. Contingency procedures to include lost link, divert, and flight termination

vii. Hazards unique to the flight being flown

d. Programs relevant auto pilot information

i. GEO Fence coordinates

ii. Drop locations

iii. Los t communication landing location

5. Crew agrees to commence operations

6. Flight Operations Commence

7. Flight Operations End

8. PIC Revokes any Notams or disclosures required for flight operations

9. PIC logs relevant flight data into logbooks

10. PIC releases crew1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

Flight Survey A survey of the flight operations area is an integral risk management strategy required for UAS flight operations. No flight operations shall be allowed without a PIC derived flight survey. The key elements to a proper flight survey are proximity to personnel and property, launch and recovery obstructions and operating areas

, aircraft ditch locations, crew placement and safety

concerns.

Risk Assessment

A risk assessment will be developed daily and note specific weather and other area hazards. This

worksheet calculates risk and derives a value of perceived risk. A high value risk assessment

score will deny flight operations.

Pre Flight Brief to Crew

This item is critical to a successful flight operation. The PIC weighs all the relevant factors and

then briefs the crew for a successful mission.

Maintenance The maintenance program that M3 Consulting Group utilizes for all of its UAS include an annual inspection and a 100 hour inspection including the use of preflight and post flight inspections.

The PIC is the final arbitrator as to the airworthiness of the aircraft.

Each specific flight vehicle is issued an aircraft logbook that contains all maintenance actions.

Training Program

M3 Consulting Group utilizes a training program for its UAS operators and observers. This program stresses 14 CFR part 91 requirements and UAV specific training. The maintenance program is an add

- on to this training program. Each UAS has its own specific q ualified

maintainers.

Communication Frequencies The Hummingbird UAS utilizes two forms of communication, the R/C transmitter and the

Ground Control Station ( GCS ) radio modem. The R/C transmitter uses a 2.4GHz band. The radio modem operates in the 900MHz band.

The Desert Cardinal UAS utilizes two forms of communication, the R/C transmitter and the GCS

radio modem. The R/C transmitter uses a 2.4GHz band. The rad io modem operates in the
900MHz band.

The SOLO UAS utilizes the 2.4GHz band for all communication.

The FCC classifies the 900 Mhz and the 2.4Ghz band as public use bands open for the public’s

use.1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

Pilot and Observer Provisions

 Pilot Qualifications: M 3 Consulting Group UAS pilots interacting with ATC shall have sufficient expertise to perform that task readily. Pilots must have an understanding of and comply with Federal Aviation Regulations applicable to the airspace where the UAS will operate. Pilot s must have as a minimum a Private Pilot License . Pilots must have in their possession a current second class (or higher) airman medical certificate that has been issued under 14 CFR 67, Medical Standards and Certification. 14 CFR 91.17, Alcohol or Drugs, applies to UAS pilots. Pilot will have satisfactorily completed the M3 Consulting Group UAS Training. Pilots will have completed a CRM training event reflected in FAA AC
120.51E.

 Observer Qualifications: Observers must have been provided with sufficie nt training to communicate clearly to the pilot any turning instructions required to stay clear of conflicting traffic. Observers will receive training on rules and responsibilities described in 14 CFR 91.111, Operating Near Other Aircraft, 14 CFR 91.113, Right

- of

- Way Rules and 14 CFR 91.155 Basic VFR weather minimums. Observers must have in their possession a current second class (or higher) airman medical certificate that has been issued under 14 CFR 67,
Medical Standards and Certification. 14 CFR 91.1 7, Alcohol or Drugs, applies to UA observers. Observers will have in their possession a pair of binoculars. Observers will have satisfactorily completed the Desert Cardinal UAS observer training. Observers will have completed a CRM training event reflect ed in FAA AC 120.51E.

Pilot

- in

- Command (PIC)

– Visual Flight Rules:

 The PIC is the person directly responsible for the operation of the UAS. The responsibility and authority of the pilot in command as described by 14 CFR 91.3

.

 The PIC must possess as a minimum a private pilot license and must keep their aeronautical knowledge up to date.

 The PIC does not necessarily have to be physically operating the radio transmitter but must be in a position to direct the flight and is respon sible for all activities.

Pilot Currency

– Visual Flight Rules:

 Pilots will not act as a PIC unless they have had three qualified proficiency events within the preceding 90 days.

o The term “qualified proficiency event” is a UAS

- specific term necessary du e to the diversity of UAS types and control systems.

o A qualified proficiency event is an event requiring the pilot to exercise the training and skills unique to the UAS in which proficiency is maintained.

o Proficiency events can be actual UAS or RC flights

o A pilot that loses currency can regain qualification by having a training event monitored by a qualified pilot.1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

PIC Responsibilities:

 Pilots are responsible for a thorough preflight inspection of the UAS. Flight operations will
not be undertaken unless the UAS is airworthy. The airworthiness provisions of 14 CFR 91.7, Civil Aircraft Airworthiness apply.

 One PIC must be designated at all times and is responsible for the safety of the UAS and persons and property along the UAS flight path.

 The UAS pilot will be held accountable for controlling their aircraft to the same standards as the pilot of a manned aircraft. The provisions of 14 CFR 91.13, Careless and Reckless Operation, apply to UAS pilots.

 Pilot will check NOTAMs prior to flight to e nsure that the flight NOTAM is posted and there are no conflicting NOTAMs for the flight area.

 Pilot will check the weather to ensure that there will be VFR conditions for the duration of the flight.

 Pilot will review aeronautical charts for the planned flight area and determine if there are any ATC agencies that will need to be contacted and have available radio frequencies and phone numbers, and check for airways and approach/departure corridors in the area of the planned flight.

 Pilot will perform a ground based f light survey, prior to flight.

 Pilot will have in their possession current sectionals and AFD for area of flight operations

Observer Responsibilities:

 Observer will ensure that adequate airspace de

- confliction has been ensured and NOTAM’s are published f

or the day’s operation.

 Observer will ensure that preflight briefings have been completed and crew is briefed.

 Observer will ensure that while in flight the UAS stays clear of any conflicted air traffic.

 Observer will ensure prior to UAS recovery that the area is clear of personnel and vehicles to maintain 500 feet of separation.

Observer Currency:

 Observers shall have yearly periodic training on UAS Operations and Part 91 refresher.

PIC and Observer Duty Time Restrictions:

The PIC and Observer team of the UAS shall not accept a flight operation without adequate prior crew rest. This is described as 8 hours of continuous rest within the previous 24 hours. Additionally:

 Crew shall not accept scheduled flight operations that extend past 10 hours of on duty time from the start of operations.

 Each Pilot and Observer will complete CRM training program based on FAA AC 120.51E Crew Resource Management Training.1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

Maintainer Qualifications:

The M3 Consulting Group UAS program will ensure that extra training is provided for UAS personnel that are tasked to perform maintenance on the UAS. Each UAS crew member will have the ability to perform a pre and post flight inspection. It is in the best interest of the

progra m to ensure that sufficiently trained personnel proceed past this inspection and perform further maintenance. These personnel shall have the additional title of UAS Maintainer.

This training will be conducted during the UAS Operator Training Program. S elected personnel will be given additional hands on instruction and be given contact information for field maintenance problems.



## M3 Consulting Group

UAS Syllabus for Operator Training

Description During this course each student will go through two phases of training. The first phase will be classroom instruction to give students the basic concepts of UAS operations . Students will learn: airspace, concept of flight, characteristics of the specific UAS, maintenance procedures and mission planning. This w ill ensure that the students understand the fundamentals of flight and
the specific UAS.

The second phase of the course will be conducted at a flight range. The students will receive the individual training required to safely operate the aircraft. M3CG anticipates that each aircraft operator will require a differing amount of instruction to operate safely. Ample time will be set aside to accomplish this task.

Instructors

The M3 Consulting Group UAS Operator course will be taught by trained and certifie d M3 Consulting Group UAS instructors. These instructors will possess UAS flight experience and have completed formal instructor training and certification. This formal training will be conducted and managed by the M3CG chief pilot. This ensures that the instruction program is up to date with the current operational procedures employed the aircraft manufacturer, M3CG.

The instructor will train students to a measurable standard while providing experience and knowledge from current field operations and stan dard operating procedures set forth by the chief pilot. This course of instruction is designed to update with the latest equipment incorporated into the aircraft as well as current tactics employed by M3CG.

Course Objectives

 Understand basic Aeronautics a nd concept of flight

 Understand Airspace and FAA regulations regarding operations in the NAS

 Introduce students to the specific UAS1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

 Understand and conduct field maintenance for the UAS

 Operate safely the UAS

 How to conduct currency flights for operators

Course Topics

 FAA and Airspace

 Concept of Flight

 System Overview

 System Assembly

 Mission Planning

 Ground Control Station (GCS) operation

 Take

- off procedures

 Inflight procedures

 Landing procedures

 Maintenance procedures

 Currency flights

 Incident reporting

 Crew Resource Management

Evaluation Each student will be evaluated during both phases of training. Each evaluation will be based on a pass or fail grade. At the completion of the live flight phase there will be an instructor
evaluation for each student. The instructor will evaluate if the student can safely operate the specific UAS. This will be a pass/fail evaluation for each of the students.

Training Day One Schedule

Administrative Class handouts and safety information.

FAA and Airspace Brief Give general instruction on FAA COA procedures and airspace.1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

UAS info Demonstrate how the aircraft is assembled and operates on a static display.

Mission planning Demonstrate on a GCS how to set up a defined area to operate in and inform of safety features to keep aircraft in a defined

area.

GCS Operation How the GCS communicates with the aircraft and troubleshooting information. Define how to load a mission.

Take

- off procedures Give instruction on how to safely operate the aircraft during this phase of flig ht. Instruct emergency procedures. Define how to set up the area for a safe take

- off.

In flight procedures Give instruction on how to safely operate the aircraft during this phase of flight. Instruct emergency procedures.

Landing procedures Give instr uction on how to safely operate the aircraft during this phase of flight. Instruct emergency procedures. Define how to set up the area for a safe recovery.

Maintenance procedures Instruct on how to repair minor damage and general
maintenance of the aircraft.

Instruct how to maintain

currency Inform students on how to maintain currency.

Incident reporting Inform student how to report mishaps and emergencies.

Crew Resource Manage ment Instruct principles of CRM.

End of phase one test Evaluate and give remedial training.

Training Day Two Schedule and Phase exam

Assemble UAS Yes NO Perform Preflight as operator and ground crew Create Mission plan Waypoints, Loiters, Fail safes
Launch UAS Operate UAS inflight Operate UAS in Altitude Mode Operate UAS in Manual Mode1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

Operator understands and is proficient at each section of the
GCS Conduct stall recovery Repair and maintain UAS Log all flights and maintenance
items Set up and conduct landing Proficient at Manual landings Perform post flight
Site break down Students can conduct a proper currency flight

UAS Maintainers The UAS program will ensure that extra training is provided for UAS personnel that are tasked to perform maintenance on the UAS. Each UAS crew member will have the ability to perform a pre and post flight inspection. It is in the best interest of the pro gram to ensure that sufficiently trained personnel proceed past this inspection and perform further maintenance. These personnel

shall have the additional title of UAS Maintainer.

This training will be conducted during the UAS Operator Training Program. Selected personnel will be given additional hands on instruction and be given contact information for field maintenance problems.

Safety Safety is of paramount concern to M3 Consulting Group UAS operations and the SIT Program. Emergency and Normal proce dures have been developed for each airframe that M3 Consulting Group utilizes. These same procedures have been utilized successfully on COA# 2014

- WSA

225. The UAS operations described for exemption 333 will not affect NAS safety as:

 The airframes have be en engineered and tested for UAS operations

.

 Operat ions will be conducted below 200 feet AGL

.

 An observer will be present to comply with UAS See and Avoid precautions

.

 All operations will be conducted utilizing line of sight and the UAS will venture no

fur ther than 1⁄2 NM from the Observer.

 M3 Consulting Group currently operates UAS in the NAS utilizing COA# 2014

- WSA

225.

 The PIC and Observer will undergo company and UAS specific training.

 The UAS will not be operated within 500 feet of any person or vehicle during the in

flight portion of the UAS operation.1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

 Operations will be conducted in class G airspace during daylight hours in VMC conditions using Class E visibility and weather standard s stated in 14 CFR 91.155.

 The UAS will not weigh over 55LBS.

 Operations will not occur over major cities

– operations will be centered in rural areas.

 All UAS aircraft will be registered with the FAA A ircraft R egistration Branch

.

Characteristics of Area of Operations The M3 Consulting Group Survey Program is intended to operate in rural areas that are devoid of human population. Where Sterile Insect Technique ( SIT ) operations encounter personnel not associated with the UAS operation the UAS shall ma ke every attempt to circumnavigate away

from non

- associated personnel and vehicles.

River Operations River Operations are the most probable area where non associated structures and personnel may be present. Proper flight survey and risk assessment usage will be paramount to reduce risk in

this environment.

Forrest Operations Operations in forested environments are not expected to pose a hazard to non

- associated personnel. The most probable safety event will be Controlled Flight Into Terrain ( CFIT ) wi th a tree or mountain. Crew communication and preflight planning will be paramount to avoid this

hazard.

Rangeland Operations Operations in Rangeland environments are not expected to pose a hazard to non

- associated personnel. The most probable safety e vent will be CFIT with a tree or mountain. Crew communication and preflight planning will be paramount to avoid this hazard.

Proximity to Public Airports The M3 Consulting Group SIT Program will not operate from public airports. The following guideline s will be followed. Operation will not commence within:

 5 nautical miles (NM) from an airport having an operational control tower; or

 3 NM from an airport with a published instrument flight procedure, but not an operational
tower; or

 2 NM from an airport without a published instrument flight procedure or an operational
tower; or

 2 NM from a heliport with a published instrument flight procedure



### List of 14 CFR requested exemptions : 21 Subpart H

– M3 Consulting Group requests relief from the requirement to r eceive and uphold an airworthiness certificate under FAA exemption 333. This will not compromise the safety of1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

the UAS operation as the aircraft will be operating under UAS manufacturer guidance and will be operating in rural areas.

45.11

- M3 Consulting Group requests relief from the requirement to attach a fireproof identification plate to the aircraft as the UAS was not designed to accommodate the extra weight and/or physical space required for an identification plate.

Part 61

– M 3 Consulting Group requests relief from the requirements of 14 CFR part 61 which state that a commercial pilot ’ s license is required to conduct flight operations for profit or hire.

91.103(b) (2)

- M3 Consulting Group requests relief from 14 CFR Part 91.103 (b)(2) as the aircraft will not be operating from an airport environment.

91.105

- M3 Consulting Group requests relief from 14 CFR Part 91.105 as no crew member will

be onboard the aircraft

.

91.109

- M3 Consulting Group requests relief from 14 CFR Part 91.109 as no crew member may

board the aircraft.

91.119

- M3 Consulting Group requests relief from 14 CFR Part 91.119 as the PIC of the aircraft will be remotely operating the aircraft and pe rforming preflight checks within 500 feet of the

aircraft.

91.121

- M3 Consulting Group requests relief from 14 CFR Part 91 as there is no pressure sensitive or correcting altimeter located on the aircraft.

91.151

- M3 Consulting Group requests relief fr om 14 CFR Part 91 as certain UAS vehicles may only have a maximum fuel capacity, whether electric or gasoline, for under 30 minutes of flight. The UAS in this circumstance is not capable of naturally complying with 91.151.

91.203

- M3 Consulting Group re quests relief from 14 CFR Part 91.203 as the aircraft operator requests to operate without the requirement of holding an airworthiness certificate for the UAS.

91.205

- M3 Consulting Group requests relief from 14 CFR Part 91.205 as the UAS is designed

to operate without the equipment specified in 91.205.

91.207

- M3 Consulting Group requests relief from 14 CFR Part 91 as the aircraft is not designed for the payload capacity to lift or power an ELT as stated in 91.207.

91.209

- M3 Consulting Group request s relief from 14 CFR Part 91.209 as the aircraft will be operated at a low level during daylight conditions. Lack of navigation lights will not affect the safety of flight operations as the aircraft is small and an observer will be providing the see an d avoid aspect of flight separation.

91.215

- M3 Consulting Group requests relief from 14 CFR Part 91.215 as the aircraft was not designed to accommodate nor carry a transponder. The aircraft will be operating below 200 feet

AGL and will not be a hind rance to ATC nor other aircraft.1221 Chevington Ct., Dayton, OH 45459 | 480.239.8942 | uas@mc3g.us | www.m3cg.us

91.405

- M3 Consulting Group requests relief from 14 CFR Part 91.405 as the aircraft will have its own maintenance program as described by M3 Consulting Group . The PIC will be the final authority to the airworthiness of the aircraft.

91.407

- M3 Consulting Group requests relief from 14 CFR Part 91.407 as the aircraft will have its own maintenance program as described by M3 Consulting Group . The PIC will be the final authority to the airworthiness of the aircraft.

91.409

- M3 Consulting Group requests relief from 14 CFR Part 91.409 as the aircraft will have its own maintenance program as described by M3 Consulting Group . The PIC will be the final authority to the airworthiness of the aircraft.

91.417

- M3 C onsulting Group requests relief from 14 CFR Part 91.417 as the aircraft will have its own maintenance program as described by M3 Consulting Group . The PIC will be the final authority to the airworthiness of the aircraft.

Abbreviations

PIC Pilot in Command
SIT Sterile Insect Technique
AGL Above Ground Level
KTAS Knots True Airspeed
VMC Visual Meteorological Conditions
NM Nautical Mile
VTOL Vertical Takeoff and Land
SOP Standard Operating Procedures
GCS Ground Control Station
UAS Unmanned Aircraft System
CFIT Controlled Flight into Terrain

Sincerely,

Dustin Krompetz
Chief of UA S Operations M3 Consulting Group, LLC dustin.krompetz@m3cg.us