DocketManagementFacility U.S. Department ofTransportation 1200 NewJersey Avenue, SE WestBuilding Ground floor Room Wl2-140 Washington, D.C. 20590 8623 

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## u 2 Springfield, VA 22152 January 23. 2016

Re: Request for Exemption from FAA Prohibition under the Washington, D.C. Metropolitan Area SFRA ofControl Line Model Aircraft Operations at the Meadowood Special Recreation Management Area, Fairfax County, Virginia
To whom it may concern: As set forth in the attached Petition, Northern Virginia Control Line (NVCL), a model airplane club, is seeking an exemption from the prohibition ofcontrol line model aircraft operations imposed bythe FAAwithin the Washington D.C. Area SFRA with respect to its flying site at Meadowood SRMA in Fairfax County, Virginia. We are also requesting expeditedreview ofthe petitionto permit control line operations to begin atMeadowood by late March/earlyApril, the normal start ofour flying season. I, and the other members ofNVCL, share the concerns ofthe FAA and other organizations andresponsible citizens regarding the absolute necessity of protectingthe safety ofthe National Airspace System for all users and preventing the use ofan aircraft as a weapon, ormeans ofdelivering weapons, to conduct an attack on persons, property, orbuildings inthe area, andrecognize the need for appropriate regulation to achieve this goal.
Withoutprejudiceto our legal rights, the members ofNVCL believe thatthis goal can bestbe furthered through constructive dialogue withthe FAA, explaining why control line operutions nt Mcudowood pose u minimal risk to public sufety and security and, accordingly, why such operations should be exempt from the flight prohibitions currently imposed under the D.C Areu SFRA.

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Inthat regard, I and othermembers ofNVCLwould welcome the opportunity to provide clarifications regarding the petition, oranswer any questions the FAA might have concerning the nature ofcontrol-line model airplane flying in general, and the operations at Meadowood in particular. We wouldbehappyto meetwith FAA representatives to discuss these issues on a face-to-face basis. Inparticular, we invite FAA representatives to visit our flying site at Mcadowoodto obtain a lirst-hand view ofhow the terrain teatures ofthe site and our operational procedures contribute to a safe and secure flying environment. Weather permitting, we would be delighted to demonstrate a control line model intlight.
We thank you for considering ourviews in this petition. Should you have any questions, I can be contacted atthe above home address, atmy home telephone number (703) 451-0143 H, (703) 304-3162 (C), orby e-mail at fidmjd({i<verizon.net. Sincerely,

FrankDobrydney, President Northern Virginia Control Line**Je,,.~** o,, 

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UNITED STATES DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION PETITION FOREXEMPTION

Petitioner: This petition for exemption is submitted onbehalfofNorthern Virginia Control Line (NVCL), a Virginia corporation, by FrankDobrydney, President, 8623 James CreekDrive, Springfield, VA 22152; phone: (703) 451-0143 (H), (703) 304-3162 (C); e-mail: fjdmjd@verizon.net. Specific Sections ofTitle 14 ofthe Code ofFederal Regulations from which Petitioner Seeks an Exemption: The following subsections ofSubpart V ofTitle 14 ofthe C.F. R.- Washington, D.C. Metropolitan Area Special Flight Rules Area (SFRA): §93.331(Purpose and applicability ofthis subpart); §93.333 (Failure to comply withthis subpart); §93.335 (Definitions); §93.337 (Requirements for operating in the DC SFRA); §93.339 (Requirements for operating inthe DC SFRA, including the DC FRZ);and §93.341 (Aircraft operations in the DC FRZ); together with Advisory Circular AC No. 91-57A, September 2, 2015, ModelAircraft OperatingStandards, Notice N JO 7210.891, November 25, 2015, UnmannedAircraft Operations in the NationalAirspace System (NAS), including any revisions to orreplacements for the aforesaid rules and regulations, as well as any otherrelevant documents issued by the Federal Aviation Administration (collectively, the "Measures").
The Extent ofReliefsought by Petitioner and the Reasons Petitioner Seeks the Relief Petitioner seeks relieffrom the Measures to the extent thatthe Measures prohibit the operation ofcontrol line model aircraft at the Meadowood Special Recreation Management Area (SRMA), Fairfax County, Virginia (Meadowood). Meadowood is within the 30-mile radius from ReaganNational Airport, and is, therefore, within the Washington, D.C. Metropolitan Area SFRA. In addition, although the FAANoticePetition for Exemption orRulemaking states thatpetitions for exemption mustbe sent 120 days before the exemption takes
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effect, NVCL respectfully requests the FAA to provide expedited review ofthe petitionto permit control line operations to begin at Meadowoodby late March/early April, 2016, the normal start ofour flying season. NVCL is a model airplane club chartered by the Academy ofModel Aeronautics (AMA) (AMA CharterNo. 308). While membership numbers fluctuate from year-to-year, NVCL membership currently consists of 18 active members. As provided in its constitution, the purposes ofNVCL are: a. "To support and promote the hobby and sport ofcontrol line model aviation in Northern Virginia; b. "To secure and maintain a public control line flying site in Northern Virginia; c. "To serve the youth ofNorthern Virginiaby providing training in control line model airplane building and flying; d. "To establish a betterunderunderstanding and appreciation, onthe part ofthe public and the local, state, and Federal government ofthe importance and benefits ofcontrol line model aviation."
In furtherance ofthese goals, NVCL, overthe years, has engaged in various community outreach activities to promote control line model aviation by encouraging public participation in the hobby. Such activities have included demonstrations ofcontrol line precision aerobatics and conducting introductory control line flights intrainers for members ofthe public, underthe direct control of experienced members ofNVCL, at suchvenues as the Udvar-Hazy Center ofthe National Air and Space Museum, "Dulles Days" at Dulles Airport, and at local schools and churches. All activities ofNVCL are conducted strictly on a hobby or recreational basis, withoutremuneration. Operations at Meadowood: Meadowood is owned and operatedbythe Bureau of LandManagement ofthe U.S. Department ofthe Interior (BLM). There are two flying circles in the lower meadow ofthe westparcel ofMeadowood (See the schematic map attached as Attachment A, a Google photograph ofthe site attached as Attachment B, and photographs ofthe two circles attached as Attachment C.) These circles are used solely for the recreational purpose offlying control line model airplanes. They were installed by members ofNVCL and maintained for use ofclub members and control line flyers ofthe general public while the property was underprivate ownership, with the permission ofthe landowner. Underthe current direction ofBLM, the circles atMeadowood are reserved for the flying ofcontrol line models only (no free flight or RIC models or other UAVs) by
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the general public 7 days a week during daylight hours only. The use ofalcohol at the site is prohibited. NVCL members maintain the circles, at their own expense, time, and labor and keep fire extinguishers and a first aid kit on site. Although the control line circles are opento the general public, the principal users ofthe circles are NVCL members and their guests. NVCL has a Special Recreation Permit from BLMto conduct an annual control line aerobatic contest at Meadowood. This event, which typically attracts approximately 25-30 contestants from Virginia and nearby States, is formally sanctioned bythe AMA. This means that the contest is open onlyto AMA members, and is conducted according to strict AMA contest safety standards. The control line flying circles at Meadowood are located approximately 1,000 feet from the entrance and main visitorparking lot for the west parcel ofMeadowood, and is accessible only by a dirt road. There is a small mowed grass parking lot at the site (maintained by NVCL) where users ofthe flying circles canparktheir cars while using the facility. Vehicular access to the west parcel, including the flying site is restricted by a metal gate that is secured by a combination lock provided and maintained byNVCL. NVCL provides BLMwith the combination, which is changedperiodically. When NVCL hosts its annual precision aerobatic contest, the gate is left open during the hours ofthe contestto permitpublic access to the site. In addition to these security measures, BLM secures the gate with a second combination lock during the hours whenthe westparcel is closed. BLM does not provide NVCL withthe combinationto this second lock. Control line models: Unlike other forms ofmodel aviation, such as free flight or radio control, control line models are unique inthat for the entire duration ofthe flight ofthe model, the aerodynamic control ofthe model's elevation is controlled solely by means offlexible lines firmly attached on one endto the model, and on the other endto a handle held by the pilot. 1 These control lines are attached to the model and the handle for the entire duration ofthe flight. Accordingly, for the entire duration ofthe flight, the flight path ofthe model is limited to the surface of a hemisphere, with the pilot in the center ofa circle whose radius equals the length ofthe control lines betweenthe model andthe handle held by the pilot. The handle held bythe pilot is connected, through wires, a bellcrank, and a pushrod, to the model's elevators, and in some cases, to other control surfaces. This enables the pilotto control "up" or "down" movements ofthe model atthe end ofthe control

1UnderAMArules, radio control is permitted in control line models only to perform secondary functions, such as to retract or extend landing gear, and mustbe underthe direct control ofthe pilot, and may be further restrictedunder the rules for particular events, as notedbelow withrespect to Precision Aerobatics. Relatively few control line models make any use ofradio control, and none have been observed at Meadowood. 3

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lines. As the model conducts its flight, the pilot rotates with the model, so that the model is always directly in front ofthe pilot. Control line models flown at Meadowood are flown in accordance with AMA rules prescribing the minimum diameter ofwire, or other material ofequivalent strength, used for control lines, based upon the weight ofthe model. In all AMA-sanctioned contests, the entire control system is subject to a pull-test, based onthe weight of the model, before the model canbe flown. Control handles are secured to the pilot's wrist by a safety thong to prevent the accidental release ofthe model. Models are powered eitherby an internal combustion engine orby an electric motor. Internal combustion engines run on a methanol-based fuel, not gasoline. They generally fall under the categories ofbeginner (trainer), sport, o.r competition precision aerobatic (stunt) models. Wingspans onmodels flown at Meadowood range from about 18 inches to 60 inches, with the majority ofmodels in the 40-55 inchrange and weighing less than 60 oz. Most models flown at Meadowood come within the precision aerobatic category. Such models are limited to engine displacements of.92 cubic inches or less, or electric motors having a maximum no-load voltage of42 volts. As a practical matter, most models have a displacement of.65 cubic inches or less, or their electric equivalents, Control lines are limited in length to70 feet. In control line precision aerobatics contests, fights are limited to 8 minutes duration. Radio control is permitted only to control the retraction or extension ofthe landing gear and a one-time irreversible cut-offofthe engine or motor. Very few control line stunt models use radio control for any purpose. Pilots ofprecision aerobatic models arejudgedby the precision with which they perform 15 prescribed maneuvers. Photographs oftypical models flown at Meadowood are attached as Attachment D.
How Petitioner's Request Would Benefit the Public as a Whole: The control line facility at Meadowood is the only dedicated control line flying site in the State ofVirginia, and one ofonly a few on Federal property nationwide. It complements the other recreational activities offered to the public at Meadowood, such as horse-back riding, trail biking, hiking and bird-watching. Itprovides a site for local control line modelers to fly their models and serves as a site for an annual major Mid-Atlantic-areaprecision aerobatic contest. Control line flying and the associated building ofmodel airplanes help support STEM education locally. Model airplane building is taught at a local school (Frost
4Intermediate) by three NVCL members. Students in the program at Frost Intermediate have flown control line models in the control line circles at Meadowood. These activities provide an introduction to topics such as strength of materials and blue-print reading, both supportive ofSTEM-related careers. Model airplane building is also taught at West Potomac High School to support technology and preparatory engineering education. NVCL has also hosted other youth groups at Meadowood to introduce them to control line flying. Reasons why the exemption would not adversely affect safety, or how the exemption would provide a level ofsafety at least equal to the existing rule: Control line model airplane flying in general, and control line operations at Meadowood in particular, pose minimal, ifany, risk to other users ofthe National Airspace System, people or property on the ground, or any other threat to national security.
14 C.F.R. § 93.311, (Purpose and applicability of

... [Subpart V.

- Washington D.C. Metropolitan Area Special Flight Rules]) states, in part, "The purpose ofestablishing this area is to facilitate the tracking of, and communication with, aircraft to deter persons who would use an aircraft as a weapon, or as a means ofdelivering weapons, to conduct an attack on persons, property, orbuildings in the area." Control line models, by their very nature, are inherently unsuitable for this purpose. Even ifa person were to deliberately release the handle while the model was in flight, the model would fly erratically and would very likely crash quickly in the immediate vicinity ofthe flying circle. In this connection, it is important to note that the control line circles at Meadowood are located in a depression, are surrounded by shrubs and tall trees and are located at a considerable distance from any roads, structures or other activities conducted at Meadowood. (See Attachments A-C.) These same considerations would also apply to mitigate any danger caused by the accidental release ofthe handle from the hand ofa pilot. The requirement that the handle be attached to the wrist ofthe pilot by means ofa safety thong while the model is airborne minimizes the risk ofa release ofthe model in the unlikely event the pilot unintentionally releases the handle.

5Likewise, the AMA requirement for conducting a pull test on the control system of a model at all contests prior to flight minimizes the risk ofa control line wire break in flight. Even ifone line were to break, it is unlikely thatboth lines would break (nearly all control line models are controlled by a two-line system) and the force of the line remaining attached to the model (either full "UP" or full "DOWN") would cause the model to crash within the flight circle.
Because ofthe minimal damages posed by the operation ofcontrol line models in general and, specifically, the particular geographical features ofthe Meadowood site, the exemption ofcontrol line flying at Meadowood from the prohibition currently in etiect under the Washington, D.C. Metropolitan Area SFRA would result in a level ofsafety essentially equal to that under the existingprohibition. 

### Summary for Publication in the FederalRegister: Northern Virginia Control Line seeks an exemption from 14 C.F.R. §§ 93.331 through 93.341 and other relevant law pertaining to the Washington D.C. Metropolitan Area Special Flight Rules Area to permit the operation ofcontrol line model aircraft at the Meadowood Special Recreation Management Area, Fairfax County, Virginia.
Respectfully Submitted by: 

# -.:?**~ ~**  Frank Dobrydney, President Northern Virginia Control Line
Date: I

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### AttachmentAo-**'J~** I

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# Farm Resource Protedion At:eas

2000

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# Ill Resource Protection Areas (RPA) 

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No wananty Is made by the Bureau of land Manaoement a& to the accuracy. reliability, or**com~leteness** ofthis data for individual use or aggregate use with otherdata. -=-·'"" ··r.;-···- -·--**'·~··** -· .. -· --·-· U.S. Department of the fhtetior Bureau of Land Management**E~tern** States March 2002

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### AttachmentBMeadowood Recreation Area

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