**Vista	Del	Mar	Middle	School**

1130	Avenida	Tale ga San	Clemente,	CA	92673 Chuck	Hobbs Tech	Processes	Teacher 949.234.5955 949.940.0262fax www.vdm.schoolloop.com
**Petition	for	Exemption	and	Relief	from	Spec i** **fic	Regulations	of	Title 14	of	the**  **Code	of	Federal	Regulations	Pursuant	to	Section	333	of the	FAA	Modernization**  **and	Reform	Act	of	1012	(Public	Law	112**

**- 95)	Regarding	Commercial**  **Employment	of	Unmanned	Aircraft	Systems (** **UAS)**

I. **Petitioner’s	Description** Vi sta	Del	Mar	Middle	School	(VDM)	is	a	publ ic	middle	school located	within the	Capistrano	Unified	School	District.	The	primary	mission	of	VDM	is	to	expand	the learnin g	and	knowledge	of	our	students to	the	greatest	extent	possible,	in	keeping with	that	missio n	the	Tech	Processes	Teacher	Mr.	Chuck	Hobbs	is	always	looking toward	future	technology	integration	and would	like	to	request	an	exemption	to utilize	small	unmanned	aircraft	systems	(UAS)	in	his	education	efforts ,	pursuant	to Section	333	of	the	Federal	Avi ation	Administration	(FAA)	Modernization	and Reform	Act	of	2012	(the	Reform	Act),	from	Federal	Aviation	Regulations	(FARs) identified	below,	allowing	commercial	operations	of	small	unmanned	aircraft systems	(UAS )

.
**II. Relevant	Statutory	Authority**  This	petition	for	exemption	is	submitted	to	fulfill	Congress’	goal	in	passing Section	333(a)	through	(c)	of	the	Reform	Act.	Congress	has	directed	the	FAA	“to safely	accelerate	the	integration	of	civil	unmanned	aircraft	systems	into	the	national airspace	system.”	Pursuant	to	Section	333	of	the	Reform	Act,	the	FAA	Administrator is	to	consider	whether	certain	UAS	may	operate	safely	in	the	National	Airspace (NAS)	before	completion	of	the	formal	UAS	rulemaking,	based	on	the	following considerations:

The	UAS’s size,	weight,	speed,	and	operational	capability; Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas;	and
Operation	of	the	UAS	within visual	line	of	sight	of	the	operator.
Pursuant	to	49	U.S.C.	§	44701	(f),	the	FAA	Administrator	h as	authority	to	grant exemptions	if	the	request	is	found	to	be	in	the	public	interest.**III.	Qualifications	for	Approval	under	Section	333	of	the	Reform Act**  The	proposed	operations	in	this	petition	for	exemption	qualify	for	expedited approval	under Section	333	of	the	Reform	Act.	Each	of	the	statutory	criteria	and other	potential	relevant	factors	are	satisfied.	The proposed	operations	would	permit the	use	of	small	and	relatively	inexpensive	UAS	under	controlled	conditions	in	Class G	airspace	with	alti tudes	limited	to	400 ft. agl.	The	focus	of	the operations	would	be to	introduce	students	to	advanced	a erial	photography	for	our	video	production	class and	give students exposure	to	new	technology	in	our	Tech	Processes	class.

The	UAS	to be	used	weighs	les s	than	four	(4)	pounds,	including	payload. Operation	of	the	aircraft	will	be	limited	to	VFR	conditions	and	winds	under	15 kn ots.	The	UAS to	be	used	is	a small	4 rotor	copter	aircraft. The	UAS	will	not	be operated	at	speeds	greater	than	30	knots.	The	UAS	wi ll	be	operated	within	visual line	of	sight	(VLOS)	of	the	pilot	in	command	(PIC)	with	the	aid	of	a	visual	observer (VO).
**IV.	Training	and	Proposed	Operations A.	Tr** **aining:** The current	PIC holds	an	Airline	Transport	Pilot	(ATP)	rating and a	current	FAA	Flight	I	Medical. During	training,	proficiency,	and	experience building	flights,	all	persons	not	essential	for	flight	operations	will	be	consider e d nonparticipants,	and	the	PIC	will	operate	with	the	appropriate	distance	from nonparticipants in	accordance	with	14CFR	§	91.119. **B. Proposed	Operations:**  All	proposed	UAS	operations	wi ll	be	c onducted over	school	fields	adjacent to	the	school	campus .	All	flights	will	be	conducted	under VFR	conditions	during	daylight	hours	with	wind	speeds	less	than	1 5	knots.	All flights	will	remain	in	visual	line	of	sight	to	the	PIC	(VLOS)	and	Observer	(VO).	All ope rations	will	occur	over	school	property. Altitudes	will	be	limited	to	below	400 ft. agl	and	the	location of	the	school	is more	than	5	miles	from	public	airports	with operating	towers,	more	than	3	miles	from	public	airports	without	towers	and	more than 1	mile	from	private	airports. Prior	to	any	flight,	the	UAS	will	undergo	a preflight	insp ection,	b efore	system	power	up,	the	status	of	the	available	batteries
will	be	verified	and	only	used	if	the	level	of	charge	is	sufficient	for	the	planned	flight. In	addition,	the	flight	area	will	be	cleared	of	all	non

- essenti al	perso nnel.	Upon successful	preflight,	th e	PIC	with	observer	will check	to	verify	the	flight	area	is cleared	of	personnel	and	spectators	before	the	propeller	on	the	UAS	begin	to	turn. Only	then	will	the	UAS	depart	the	takeoff/landing	area	for	the	designated	mission. An	observer (VO) will	be	required	for	all	flights	standing	in	close	proximity	to	the PIC with	the	responsibility	to	report	to	the	PIC	any	issues that have	the	potential	to interfere	with	the	flight	and	the	safety	of	surrounding	individuals	and	objects.	Upon mission	completion,	the	UAS	will	be	inspected	and	any	issues addressed	before	the next series	of	flights. **C.	Unmanned	Aircraft	System** : VDM’s proposed	UAS	operations	would u se 3D Robotics Solo drone	copter .	The	3DR	has	four	880kV	motors,	f light	is controlled by	two	(2)	1GHz	computers	with	one	in	copter	and	one	in	the	controller,	connected by a	powerful	dedicated	Wi

- Fi signal,	additionally	the	signal	will	allow	a	GoPro camera	to	provide	live	HD	video	streams	to	a	mini	IPAD	screen. The state

- of

- the

- artPixhawk	2 autopilot	will	be	use d	to	set	advanced	in

- flight	profiles. The	aircraft	can

also be	programmed	to	not	fly	above	400	feet	AGL	and	to	not	fly	outside	of	a	pre

determined	flight	zone. T he	3DR	has	numerous	failsafe function s	built

- in;	auto takeoff/landing,	lost	signal,	low	battery,	emerg ency	brake,	and	return	home	modes all	add	extra	level s	of	safety. **V.	Regula tions	from	which	Exemptions	are**  **requested** Vista	Del	Mar	Middle	School	seeks	exemption	of	the	following	FAR’s

**FAR’s	14	CFR	Part	21,	Subpart	H:	Airworthiness	Certificates	and	14	CFR §	91.203(a)(1)**  **14	CFR	§	61.56	Flight	review 14	CFR	§	61.113:	Private	pilot	privileges	and	limitations:	Pilot	in**  **command 14	CFR	§	91.7(a):	Civil	aircraft	airworthiness** 
**14	CFR	§	91.119(c):	Minimum	safe	altitudes 14	CFR	§	91.121:	Altimeter	settings**  **14	CFR	§	91.151(a):	Fuel	requirements	for	flig ht	in	VFR	conditions	(day)** 
**14	CFR	§§	91.405(a):	Maintenance	required;	91.407(a)(1):	Operation after	maintenance,	preventative	maintena**  **nce,	rebuilding,	or	alteration 91.409(a):	Inspections;	91.417	(a)(b):	Maintenance	records** 
**14	CFR	Part	21;	Subpart	H: Airworthiness	Certificates	and	14	CFR**  **§91.203(a)(1)** Vista	Del	Mar	Middle	School requests	an	exemption	from	14	CFR	Part	21,	Subpart	H, which	establishes	the	procedures	for	attaining	airworthiness	certificates	required by	14	CFR	§	91.203(a)(1).	The	Reform	Act	allows	the	FAA	to	exempt	aircraft	from the	requirement	of	an	airworthiness	certificate	in	consideration	of	the	size,	weight, speed,	operational	capability,	and	proximity	to	airports	and	populated	areas	of	the particular	UAS.
**Equivalent	Level	of	Safety :**  The	UAS	to be	operated	is	the	3DR	Solo	drone which weighs	less	than	4 pounds	including	payload,	carries	no	pilot	or	passengers,	carries no	flammable	liquid	fuels,	and	operates	within	a	pre

- determined	flight	zone. Furthermore,	the	PIC	and	VO	will	determin e	th e	airworthiness	of	the	3DR	Solo UASprior	to	each	flight,	by	adhering	to	safety	guidelines set	forth	in	the	3DR User

Manual

. **14	CFR	§	61.56:	Flight	review** Vista	Del	Mar	Middle	School requests	exemption	from	14	CFR	§	61.56,	which subjects	the	pilot	in command	(PIC)	to	flight	review	requirements	consisting	of	one (1)	hour	of	flight	time	in	an	aircraft	in	which	the	PIC	is	rated	on	his	or	her	pilot certificate	and	one	(1)	hour	of	ground	training.	The	flight	review	requirements	set forth	in	14	CFR	§	61.56 would	have	little	relevance	to	the	safe	operation	of	the	small UAS	inte nded	for	use	in	VDM’s operations. **Equivalent	Level	of	Safety:** An	equivalent	level	of	safety	will	be	achieved	by following training	procedures	to	ensure	the	PIC	skill	level	is	suff icie nt	to	conduct safe	operations	in	all	phases	of	flight,	including precise	mane uvering	skills	and emergency situations. **14	CFR	§	61.113:	Private	pilot	privileges	and	limitations:	Pilot	in	command** Vista	Del	Mar	Middle	School requests	an	exemption	from	14	CFR §	61.113,	limiting private	pilots	and	sport	pilots	to	non

- commercial	operations.	However,	the	UAS	will not	carry	pilots,	passengers,	or	any	living	thing	and	be	restricted	to	a	flight	zone	that is	predetermined	and	controlled	as	to	access.	The	risks	associ ated	with	the	UAS operations	are	far	diminished	from	the	risks	associated	with	commercial	operations envisioned	by	14	CFR	Part	61,	when	drafted.
**Equivalent	Level	of	Safety:** Proposed	UAS	operations	will	obtain	an	equivalent level	of	safety,	as	the	aircraft	will	carry	no	living	thing	on	board.	The	level	of	safety provided	exceeds	that	provided	by	a	single	individual	holding	a	commercial	pilot certificate	operating	a	conventiona l	aircraft.
**14	CFR	§	91.7(a)	Civil	aircraft	airworthiness** Vista	Del	Mar Middle	School requests	an	exemption	from	14	CFR	§	91.7(a),	which requires	that	civil	aircraft	be	in	airworthy	condition to	be	operated.	Since	the	3DR Solo UAS	ha s	no	airworthiness	c ertificate, there	is	no	regulatory	standard	for determining	the	airworthiness	of	the	UAS. **Equivalent	Level	of	Safety:** In	accordance	with	14	CFR	§	91.7(b),	the	PIC	will determine	whether	the	UAS	is	in	a	condition	for	safe	flight	by	complying with procedur es	in	the	3DR	Solo UAS	User	Manu al

. **14	CFR	§	91.119(c)	Minimum	safe	altitudes** Vista	Del	Mar	Middle	School requests	an	exemption	from	14	CFR	§	91.119(c),	which establishes	minimum	safe	altitudes	“over	other	than	congested	areas,”	in	which	an aircraft	bel ow	500	feet	AGL	may	not	operate	closer	than	500	feet	to	any	person, vessel,	vehicle,	or	structure.	In	order	to provide	the	intended	educational experience,	the	UAS	will	be	operated	below	500	feet	AGL	and	closer	than	500	feet	to persons,	ves sels,	vehicles, and	structures.**Equivalent	Level	of	Safety:** Operation	of	the	UAS	is	safer	than	traditional	aircraft

due	to	its	small	size,	lightweight,	lack	of	flammable	fuel,	and limited	speed. Additionally,	all flights	will	occur	within	the	school property	with	advanced	notice of all	UAS	operations.	The	UAS	will be	operated	in	a controlled	area.	Under	no circumstances	will	the	UAS	be	operated	so	close	to	persons,	vessels,	vehicles,	or structures	as	to	present	an	undue	hazard.
**14	CFR	§	91.121:	Altimeter	sett ings**  Vista	Del	Mar	Middle	School requests	an	exemption	from	14	CFR	§	91.121,	which states	that	when	operating	below	18,000	feet	MSL,	aircraft	not	equipped	with	a radio	shall	set	an	altimeter	to	the	elevation	of	the	departure	airport	or	an appropriate	alti meter	setting	available	before	departure.	An	exemption	is	required because	the	UAS	is	not	equipped	with	a	user	configurable	barometric	altimeter. **Equivalent	Level	of	Safety:** Complying	with	the	pre

- fl ight	procedures	in	the	3DR UAS	User	Manual	and	verifyin g	the	GPS	altitude	before	each	flight	will	provide	an equivalent	level	of	safety.	During	flight,	th e	3DR UAS	provides	an	Above	Ground Level	(AGL)	reading	in	relati on	to	its	takeoff	location.	The altitude	will	be	closely monitored	during	flight,	keeping	the UAS	below	400	feet	AGL,	ensuring	operations at	safe	altitudes.	Furthermore,	the	UAS	will	remain	within	VLOS	of	the	PIC	and	VO	at all	times. **14	CFR	§	91.151(a):	Fuel	requirements	for	flight	in	VFR	conditions	(day)** Vista	Del	Mar	Middle	School requests	an exemption	from	14	CFR	§	91.151(a),	which states	than	no	person	may	begin	a	flight	unless	there	is	enough	fuel	to	fly	to	the	first point	of	intended	landing	and,	assuming	normal	cruising	speed	to	fly	after	that	for	at least	30	minutes.	Th e	battery	powered 3DR	Solo	UAS	provides	approximately	25 minutes	of	total	flight	time.	It	is	therefore	impossible	for	the	UAS	to	meet	the requirement	of	this	section. **Equivalent	Level	of	Safety:** Planning	all	flights with	the	intent	to	land	after	20 minutes	or	if	the	3DR	d etects	a	low	battery	level	prior	to	20mins,	the	3DR	is programmed	to	return	to	home	for	an	automatic	landing.	This will	provide	an equivalent	level	of	safety.	Additionally,	unlike	traditional	aircraft,	the	UAS	will always	be	within	VLOS	and	have	no	signifi cant	transit	time	to	or	from	the	l anding area.	VDM will	only	operate	the	UAS	in	daytime	VFR	conditions	within	VLOS.
**14	CFR	§§	91.405(a)	Maintenance	required;	91.407(a)(1)	Operation	after maintenance,	preventative	maintenance,	rebuilding,	or	alteration;	9**  **1.409(a) Inspections;	91.417(a)	and**  **(b)	Maintenance	records.** Vista	Del	Mar	Middle	School requests	an	exemption	from	the	maintenance	and inspections	requirements	of	14	CFR	§	91.405(a),	91.407(a)(1),	91.409(a),	and 91.417(a)	and	(b).	These	regulations	apply to	maintenance	of	aircraft	holding	an airworthiness certificate,	which	the	3DR	Solo UAS	does	not	have.	Therefore	an exemption	is	required.**Equivalent	Level	of	Safety:** An	equivalent	level	of	safety	will	be	achieved	by

ensuring	that	the	UAS	is	in	working	o rder	prior	to	initiating	flight,	performing requ ired	maintenance .	All	maintenance	and	inspections	will	be	perfo rmed	in accordance	with	the	3DR UAS	User	Manual.

**VI.	Public	Interest** An exemption	for	Vista	Del	Mar	Middle	School to	use	UAS	commercially	woul d	help to	fulfill	Congress’	goal	in	assessing	whether	certain	UAS	may	operate	safely	in	the NAS.	The	exemption	is	in	the	public	interest	as	it	offers a	safe	and cost

- effective	way to	intr oduce	students	to	new and	d eveloping technologies	in	the	aviation	and photography	fields

. **VII.	Privacy** As	mentioned	above,	all	fli ghts	will	occur	over	school	land	that	has	controlled access.	Privacy	will	not	be	an	issue	where	flights	will	not	occur	over	private property. **VIII.	Publication	Summary** Th e	petitioner,	Vista Del	Mar	Middle	School seeks	exemption	from	the	following rules	to	commercially	operate	UAS	in	the	National	Airspace	to conduct	educational flights	using	a	UAS	for	aerial	video	production and	technology	studies.
**14	CFR	Part	21,	Subpart	H:	Airworthiness	Ce rtificates	and	14	CFR	§**  **91.203(a)(1)	14 CFR	§	61.56	Flight	review**  **14	CFR	§	61.113:	Private	pilot	privileges	and	limitations:	Pilot	in	command 14	CFR	§	91.7(a):	Civil	aircraft	airworthiness**  **14	CFR	§	91.119(c):	Minimum	safe	altitudes	14	CFR §	91.121:**  **Alti meter**  **settings 14	CFR	§	91.151(a)(1)(2):	Fuel	requirements	for	flight	in	VFR	conditions	(day)**  **14	CFR	§§	91.405(a):	Maintenance	required;	91.407(a)(1):	Operation	after maintenance,	preventative	maintenance,	rebuilding,	or	alteration;	91.409(a):**  **Inspection s;	91.417	(a)(b):	Maintenance	records** 

**X.	Conclusion** Vista	Del	Mar	Middle	School respectfully	submits	this	request	for	expedited exemption	under	Section	333	of	the	Reform	Act.	Given	the	small	size	of	the UAS,	the willingness to	gain	all	necessary	permiss ions,	and	the commencement	of well

planned ope rations,	the	commercial UAS	use	by	Vista	Del	Mar	Middle	School causes no	threat	to	the	general	public	or	others	using	the	National	Airspace.