Olin Way 

Needham, MA 02492-1200 

781-292-2300 

www.olin.edu 

1

March 31, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

RE: Exemption Request under Section 333 of the FAA Modernization and Reform Act of 

2012 and 14 C.F.R. Part 11 

Dear Sir or Madam, 

Olin College of Engineering (Olin), a nonprofit educational institution located at 1000 Olin Way, 

Needham, MA 02492 and Pursuant to Section 333 of the FAA Modernization and Reform Act of 

2012 ("FAA Reform Act") and 14 C.F.R. Part 11, respectfully requests exemptions from several 

provisions of the Federal Aviation Regulations ("FAR"), specifically Section 333 which 

authorizes the FAA to determine: 

1. If certain unmanned aircraft systems, if any, as a result of their size, weight, speed, 

operational capability, proximity to airports and populated areas, and operation within 

visual line of sight do not create a hazard to users of the national airspace system or the 

public or pose a threat to national security; and 

2. Whether a certificate of waiver, certificate of authorization, or airworthiness certification 

under section 44704 of title 49, United States Code, is required for the operation of 

unmanned aircraft systems identified under paragraph (1) 

We are writing to request that Olin, an owner and operator of small unmanned aircraft, be 

exempted from the Federal Aviation Regulations (FARs) listed below so that Olin may operate 

its small unmanned aircraft systems (UAS) for research on its own behalf and on behalf of other 

research groups in airspace regulated by the Federal Aviation Administration (FAA) as long as 

such operations are conducted within and under the conditions outlined herein or as may be 

established by the FAA as required by Section 333. 

Olin has been actively involved in the technical development of UAS/UAV autonomy, command 

and control research to develop potential future applications to the scientific and research 

communities; in particular mission planning, field biology, geophysics and other autonomy and 

physical science communities. 
Olin Way 

Needham, MA 02492-1200 

781-292-2300 

www.olin.edu 

2

Olin has a number of small commercial UAS/UAV platforms, primarly multicopters 

manufactured by 3DRobotics, along with a small number of small, hobbyist-level fixed wing 

UAV platforms. Pictures of representative vehicles are here: 

Figure 1 3DRobotics “Iris+” Quadcopter 

Figure 2 Hobbyking “Bixler” Fixed Wing Trainer 
Olin Way 

Needham, MA 02492-1200 

781-292-2300 

www.olin.edu 

3

All of Olin’s UAS/UAV systems are well under 55 pounds, are flown within line-of-sight of the 

operator, flown below 400 feet and during daylight hours only, and are restricted to fly only over 

Olin 

Olin has equipped every vehicle with the “PixHawk” autopilot, which is manufactured by 

3dRobotics. The autopilot has many useful functions to maintain controlled flight for teaching 

and research, most relevant of which is the ability to set limits (known as a “GPS Fence”) which 

prohibits the UAS/UAV from flying outside of a pre-defined area. 

Figure 3 3DRobotics PixHawk Commercial Autopilot 

Olin’s research is investigating the ability to locate an “interesting phenomenon,” such as a wild 

animal, a forest fire, stressed plants, etc. and dispatch a small UAS/UAV to collect detailed 

information about the location and size of the phenomenon. The operator can then capture an 

image from the vehicle’s camera and calculate the GPS position of that image. The images are 

then studied by an expert who has in interest in that phenomenon. For example, the operator 

might capture the picture of a brush fire, whereupon a firefighting team might use that picture 

and location to decide on their next course of action. At this time the research is restricted to 

ground operations and laboratory experiments. All outdoor operations are restricted to Olin 

campus property and focus solely on teaching students how to fly small air vehicles in a manner 
Olin Way 

Needham, MA 02492-1200 

781-292-2300 

www.olin.edu 

4

consistent with the Academy of Model Aeronautics Official AMA National Model Aircraft Safety 

Code.

Olin’s exemption request would permit its operation lightweight, unmanned (remotely controlled 

in line of sight) UAS's in tightly controlled and limited airspace. Specifically over Olin College 

property and, with written permission of the owners, over local farms and woodlands. It should 

be noted that none of said properties are within 5 miles of any airport. Predetermined, 

specifically marked areas of operation will allow Olin to operate within current safety parameters 

and new ones being implemented. 

Granting Olin’s request comports with the Secretary of Transportation's (FAA Administrator's) 

responsibilities to not only integrate UAS's into the national airspace system, but to" ... establish 

requirements for the safe operation of such aircraft systems [UAS's] in the national airspace 

system" under Section 333 of the Reform Act. Further, Olin will conduct its operations in 

compliance with the protocols described herein or as otherwise established by the FAA. 

The Extent of Relief Olin Seeks and the Reason It Seeks Such Relief: 

Olin submits this application in accordance with the Reform Act, 112 P.L. 95 §§ 331-334, 

seeking relief from any currently applicable FAR's operating to prevent Olin contemplated 

research and other flight operations within the national airspace system. The Reform Act in 

Section 332 provides for such integration of civil unmanned aircraft systems into our national 

airspace system as it is in the public's interest to do so. Olin lightweight UAS's meet the 

definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration of 

Olin lightweight UAS's are expressly contemplated by the Reform Act. Olin would like to 

operate its lightweight UAS's prior to the time period by which the Reform Act requires the FAA 

to promulgate rules governing such craft. The Reform Act guides the Secretary in determining 

the types of UAS's that may operate safely in our national airspace system. Considerations 

include: The weight, size, speed and overall capabilities of the UAS; Whether the UAS will be 

operated near airports or populated areas; and, Whether the UAS will be operated by line of 

sight. 

112 P.L. 95 § 333 (a). Each of these items mitigates in favor of an exemption for 

Olin. 

Olin hovering UAS's use multi counter-rotating propellers for extreme balance, control 

and stability. Olin fixed-wing UAS’s are based on proven hobby-grade model aircraft which 

were designed to be inherently light and stable. They each typically weigh less than 55 pounds, 
Olin Way 

Needham, MA 02492-1200 

781-292-2300 

www.olin.edu 

5

including camera or other equipment. Each of Olin’s small hovering unmanned aircraft are 

designed to primarily hover in place and operate at less than a 50 knot maximum speed. They are 

capable of vertical and horizontal operations but operate only within the line of sight of the 

remote control pilot. Olin’s fixed-wing UAS’s are designed to circle over an area of interest at 

low speed to provide a stable camera platform. They are designed to fly at less than 50 knots. In 

addition to the remote control pilot, Olin uses an assistant/spotter/camera operator and, if the 

team consists of students, a supervising faculty member, such that, at minimum, two Olin 

personnel, or three if two are students, govern the safe flight of an Olin aircraft at all times. 

Utilizing battery power and not combustible fuels, flights generally last between five and twenty 

minutes. Olin does not operate its UAS's with less than twenty five percent battery capacity. 

Safety systems in place include a GPS mode that allows Olin UAS's to hover in place (or circle, 

if it is a fixed wing UAS) if communication with the radio control pilot is lost and then slowly 

descend the UAS at twenty five percent battery capacity. Further, Olin’s fleet is programmed, in 

some instances, to slowly follow a predetermined set of waypoints to return to a safety point if 

communications are lost. 

Olin is not located near, nor does operate its UAS's near airports and generally does not operate 

them near populated areas. 

Olin’s operation of its fleet of small unmanned aircraft will not "create a hazard to users of the 

national airspace system or the public." 112 P. L. 95 § 3 3 3 (b). Given the small size and weight 

of Olin’s UAS's, combined with their operation in cordoned off and well-controlled areas, Olin’s 

fleet falls within Congress's contemplated safety zone when it promulgated the Reform Act and 

the corresponding directive to integrate UAS's into the national airspace system. 

The FAA has the authority to issue the exemption to Olin pursuant to the Federal Aviation Act, 

85 P.L. 726 (1958), as amended (the "Act"). Commercial and Public Benefits Granting Olin 

exemption request furthers the public interest. First, Congress has already pronounced that it is in 

the public's interest to integrate commercially flown UAS's into the national airspace system, 

hence the passing of the Reform Act. Second, Olin conducts research into safe UAS operations 

every time it flies one of its UAS's. Flight data, visual inspections, recorded observations and 

flight analyses are compiled and analyzed as a part of the research effort to further enhance 

current safety protocols. Allowing Olin to log more flight time directly relates to its research and 

its ability to further enhance current safety measures. Third, Olin has received requests to supply 

mission data to US Government agencies, such as NASA, NOAA, and the Army Research 

Laboratory. Allowing Olin to conduct these flights will assist in furthering the research efforts 

and interests of all of these agencies. 
Olin Way 

Needham, MA 02492-1200 

781-292-2300 

www.olin.edu 

6

Granting Olin’s exemption request substantially furthers the public's interest in ways known and 

currently unknown. Permitting Olin to immediately fly within the United States furthers 

advancements in publicly usable technologies or advancements in equipment available to law 

enforcement personnel, the military, and first responders with state of the art equipment that has 

the virtue of being cheaply and quickly available. 

Reasons Why Olin’s Exemption Will Not Adversely Affect Safety Or How The 

Exemption Will Provide a Level of Safety At Least Equal To Existing Rule: 

Olin’s exemption will not adversely affect safety. Quite the contrary, for the various reasons 

stated, permitting Olin to log more flight time will allow Olin to innovate and implement new 

and as of yet undiscovered safety protocols while exploring the advantages and limitations of 

computer assisted ground station monitoring. 

Olin’s UAS's weigh less than 55 pounds complete with cameras and sensors. 

Olin only operates its UAS's below 400 feet. 

Olin’s UAS's only operate for 5-45 minutes per flight. 

Olin lands its UAS's when they reach 25% battery power. 

Olin’s remote control pilots operate all Olin UAS's by Visual Line of Sight. 

Olin remote control pilots have a second spotter, plus video and telemetry backup should 

they somehow lose sight of the UAS. 

Olin’s aircraft are controlled with unaltered, hobby-grade 2.4GHz spread-spectrum radios 

for control and 900MHz radios for telemetry. Both radio systems are common standards 

used throughout the hobby / amateur community. The 900MHz radios are designed and 

sold by 3DRobotics, makers of the commercial PixHawk autopilot (seen in Figure 3). 

Olin staffs each flight with a remote control pilot and camera operator and, if the testing 

team is all-student, a faculty supervisor. 

Olin UAS's have GPS flight modes whereby they hover and then slowly land if 

communication with the remote control pilot is lost, battery power is below25% or the 

vehicle leaves the pre-determined flight area. 
Olin Way 

Needham, MA 02492-1200 

781-292-2300 

www.olin.edu 

7

Olin actively analyses electronic flight data and other sources of information to 

constantly update and enhance safety protocols. 

Olin only operates in secured areas that are strictly controlled, are away from 

airports and populated areas and have written permission from the property owner. 

Olin conducts extensive briefings prior to and after each flight, during which safety 

carries primary importance; 

 Olin always obtains all necessary permissions and permits prior to operation; 

Olin provides a level of safety at least equal to existing rules, and in nearly every 

instance, greater than existing rules. 

Summary the FAA may publish in the Federal Register: 

14 .F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and the Like. 14 C.F.R. 

21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for 

procurement of necessary airworthiness certificates in relation to FAR§ 91.203(a)(l). The 

size, weight and enclosed operational area of Olin’s UAS's permits exemption from Part 

21 because Olin UAS's meet an equivalent level of safety pursuant to Section 3 3 3 of the 

Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate 

requirement under both the Act (49 U.S. C. § 44701 (f)) and 

A. Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt 

UAS's from the airworthiness certificate requirement in consideration of the weight, size, 

speed, maneuverability and proximity to areas such as airports and dense populations. 

Olin’s UAS's meet or exceed each of the elements. 

14 C.F.R. 91.7 (a) prohibits the operation of an aircraft without an airworthiness 

certificate. As no such certificate will be applicable in the form contemplated by the 

FARs, this Regulation is inapplicable. 

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no 

pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An 

equivalent level of safety will be achieved by maintaining a manual at the flight 

operations center. The FAA has previously issued exemptions to this regulation in 

Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 

10700 and 32827. 
Olin Way 

Needham, MA 02492-1200 

781-292-2300 

www.olin.edu 

8

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as Olin’s UAS's 

utilize electronic global positioning systems and internal gyroscopes to provide spatial 

coordination. 

14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and 

registrations. They are inapplicable for the same reasons described above. The equivalent 

level of safety will be achieved by maintaining such certifications and registrations at the 

Olin research laboratory/flight operations center. 

B. 14 C.F.R. § 45.23: Marking of the Aircraft. Applicable Codes of Federal Regulation 

require aircraft to be marked according to certain specifications. Olin’s UAS's are, by 

definition, unmanned. They therefore do not have a cabin, cockpit or pilot station on 

which to mark certain words or phrases. Further, two-inch lettering is difficult to place on 

such small aircraft. The FAA has previously issued exemptions to this regulation through 

Exemptions Nos. 8738,10167, 10167A and 10700. 

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations. Pursuant to 14 C.F.R. §§ 

61.113 (a) & (b), private pilots are limited to non-commercial operations. Olin can 

achieve an equivalent level of safety as achieved by current Regulations because Olin’s 

UAS's do not carry any pilots or passengers. Further, while helpful, a pilot license will 

not ensure remote control piloting skills. Olin’s model aircraft pilot vetting and training 

programs (based upon completion of an Academy of Model Aircraft recommended and a 

self-administered UAS flight training program and internal procedures) will. Also, the 

risks attendant to the operation of Olin’s UAS's is far less than the risk levels inherent in 

the commercial activities outlined in 14 C.F.R. § 61, et seq. 

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C. F. R. § 91.119 prescribes safe altitudes 

for the operation of civil aircraft. It allows Helicopters to be operated at lower altitudes in 

certain conditions. Olin’s UAS's will never operate at an altitude greater than 400 AGL. 

Olin will, however, operate its UAS's in sectioned off areas with security perimeters, 

providing a level of safety at least equivalent to those in relation to minimum safe 

altitudes. Given the size, weight, maneuverability and speed of Olin’s UAS's, an 

equivalent level of safety will be achieved. 

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections. The 

above-cited Regulations require, amongst other things, aircraft owners and operators to 

"have [the] aircraft inspected as prescribed in subpart E of this part and shall between 
Olin Way 

Needham, MA 02492-1200 

781-292-2300 

www.olin.edu 

9

required inspections, except as provided in paragraph C of this section, have 

discrepancies repaired as prescribed in part 43 of this chapter." 

These Regulations only apply to aircraft with an airworthiness certificate. They will not, 

therefore, apply to Olin should its requested exemption be granted. Even so, Olin 

conducts an extensive maintenance program that involves regular software 

updates and constant inspection for assessment and replacement/repair of any damaged 

hardware. Therefore, an equivalent level of safety will be achieved. Olin is using 

currently manufactured UAS’s for its research which have been produced in significant 

numbers, which also allows Olin to avail itself of the higher reliability and expertise of 

the vehicle manufacturers which will further help in keeping all vehicles safe. 

F. Summary 

Olin seeks an exemption from the following Regulations: 14 C.F.R. 21, subpart H; 14 

C.P.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. § 91.7 (a); 14 C.F.R. § 91.9 

(b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. § 91.119; 14 C.F.R. § 

91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 

C.F.R. § 91.407 (a)(1); 14 C.P.R.§ 91.409 (a)(2); 14 C.P.R.§ 91.409 (a)(2); and, 14 

C.P.R.§§ 91.417 (a) & (b) to commercially operate its fleet of small unmanned hovering 

and lightweight unmanned fixed-wing aircraft and to conduct its own research and to 

supply data to other groups that request it, such as NASA, The US Army, NOAA, 

physical scientists, biologists, search and rescue. Granting Olin’s request for exemption 

will reduce current risk levels and thereby enhance safety. 

Further, Olin operates at lower altitudes and in controlled airspace. Olin has been 

analyzing flight data and other information in compiling safety protocols and the 

implementation of a flight operations manual that exceeds currently accepted means and 

methods of safe flight for these vehicles. There are no people on board Olin UAS's and 

therefore the likelihood of death or serious bodily injury is significantly limited. Olin’s 

operation of its UAS's, weighting less than 55 pounds and traveling at speeds lower than 

50 knots, in cordoned off areas will provide at least an equivalent level of safety as that 

achieved under current FARs. 

 
Olin Way 

Needham, MA 02492-1200 

781-292-2300 

www.olin.edu 

10

Olin respectfully requests that the FAA grant its exemption request without 

delay. The FAA has the authority to issue the exemption sought by Olin 

pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). 

Sincerely, 

Prof. Andrew Bennett 

Associate Professor of Mechanical Engineering 

Franklin W. Olin College of Engineering 

781-292-2522 

Andrew.Bennett@olin.edu