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 S ection 333 of the FAA Modernizatio n and Reform Act of
2012 and 14 C.F.R. Part 11

Dear Sir or Madam,

Olin College of Engineering (Olin), a nonprofit educational ins titution located at 1000 Olin Way, Needham, MA 02492 and Pursuant t o Section 333 of the FAA Modern ization and Reform Act of 2012 ("FAA Reform Act") and 14 C.F.R. Part 11, respectfully req uests exemptions from several provisions of the Federal Avia tion Regulations ("FAR"), specifi cally Section 333 which
authorizes the FAA to determine:

1. If certain unmanned aircraft syst ems, if any, as a result of th eir size, weight, speed, operational capability, proximit y to airports and populated are as, and operation within visual line of sight do not creat e a hazard to users of the nat ional airspace system or the public or pose a threat to national security; and

2. Whether a certificate of waive r, certificate of authorization, or airworthiness certification under section 44704 of title 49, Unite d States Code, is require d for the operation of unmanned aircraft systems id entified under paragraph (1)

We are writing to request that Olin, an owner and operator of s mall unmanned aircraft, be exempted from the Federal Aviation Regulations (FARs) listed be low so that Olin may operate its small unmanned aircraft syst ems (UAS) for research on its o wn behalf and on behalf of other research groups in airspace regu lated by the Federal Aviation A dministration (FAA) as long as such operations are conducted w ithin and under the conditions o utlined herein or as may be established by the FAA as required by Section 333.

Olin has been actively involved i n the technical development of UAS/UAV autonomy, command and control research to develop pot ential future applications t o the scientific and research communities; in particular m ission planning, field biology, geo physics 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, primar ly multicopters manufactured by 3DRobotics, along with a small number of small, hobbyist-level fixed wing UAV platforms. Pictures of repre sentative vehicles are here:

Figure 1 3DRobotics “Iris+” Quadcopter

Figure 2 Hobbyking “Bixler” Fixed Wing TrainerOlin 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 flo wn within line-of-sight of the operator, flown below 400 feet a nd during daylight hours only, and are restricted to fly only over
Olin

Olin has equipped every vehicle with the “PixHawk” autopilot, w hich is manufactured by 3dRobotics. The autopilot has many useful functions to maintai n controlled flight for teaching and research, most relevant of w hich is the ability to set limi ts (known as a “GPS Fence”) which prohibits the UAS/UAV from flyi ng outside of a pre-defined area

.

Figure 3 3DRobotics PixHawk Commercial Autopilot

Olin’s research is investigating the ability to locate an “inte resting phenomenon,” such as a wild animal, a forest fire, stressed plants, etc. and dispatch a sma ll 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 phenomeno n. For example, the operator might capture the picture of a brush fire, whereupon a firefigh ting 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 oper ations are restricted to Olin campus property and focus solely on teaching students how to fl y small air vehicles in a mannerOlin Way Needham, MA 02492-1200
781-292-2300 www.olin.edu

4 consistent with the Academ y 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 ti ghtly controlled and limited airsp ace. Specifically over Olin College property and, with written perm ission of the owners, over local farms and woodlands. It should be noted that none of said propertie s are within 5 miles of any airport. Predetermined, specifically marked areas of ope ration will allow Olin to opera te within current s afety parameters and new ones being implemented.

Granting Olin’s request comports with the Secretary of Transpor tation's (FAA Administrator's) responsibilities to no t only integrate UAS's into the national airspace system, but to" ... establish requirements for the safe operati on of such aircraft systems [U AS's] in the national airspace system" under Section 333 of the R eform Act. Further, Olin will conduct its operations in compliance with the protocols de scribed herein o r as otherwise established by the FAA.

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

Olin submits this application in accordance with the Reform Act , 112 P.L. 95 §§ 331-334, seeking relief from any current ly applicable FAR's operating to prevent Olin contemplated research and other flight opera tions within the national airspa ce system. The Reform Act in Section 332 provides for such int egration of civil unmanned air craft systems into our national airspace system as it is in th e public's interest to do so. Oli n lightweight UAS's meet the
definition of "small unmanned air craft" as defined in Section 3 31 and therefore the integration of Olin lightweight UAS's are expr essly 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 suc h craft. The Reform Act guides the Secretary in determining the types of UAS's that may ope rate safely in our national airs pace system. Considerations include: The weight, size, spee d and overall capabilities of th e UAS; Whether the UAS will be operated near airports or populat ed 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 o f an exemption for
Olin.

Olin hovering UAS's use multi counter-rotating propellers for e xtreme balance, control and stability. Olin f ixed-wing UAS’s are based on proven hobby- grade model aircraft which were designed to be inherently light and stable. They each typi cally 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 hover ing 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 horizonta l operations but operate only within the line of sight of the remote control pilot. Olin’s fi xed-wing UAS’s are designed to c ircle over an area of interest at low speed to provide a stable camera platform. They are design ed to fly at less than 50 knots. In addition to the remote control p ilot, Olin uses an assistant/sp otter/camera operator and, if the team consists of students, a supervising faculty member, such t hat, at minimum, two Olin personnel, or three if two are s tudents, govern the safe flight of an Olin aircraft at all times.

Utilizing battery power and not combu stible fuels, flights gene rally 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 c ommunication with the radio cont rol pilot is lost and then slowly descend the UAS at twenty five pe rcent battery capacity. Furthe r, Olin’s fleet is programmed, in some instances, to slowly follow a predetermined set of waypoin ts to return to a safety point if
communications are lost.

Olin is not located near, nor doe s operate its UAS's near airpo rts and generally does not operate them near populated areas.

Olin’s operation of its fleet of small unma nned aircraft will n ot "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 t heir operation in cordoned off and well-controll ed areas, Olin’s fleet falls within Congress's cont emplated safety zone when it promulgated the Reform Act and the corresponding directive to int egrate UAS's into the nationa l airspace system.

The FAA has the authority to i ssue the exemption to Olin pursua nt to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act"). Commercial and Pub lic Benefits Granting Olin exemption request furthers the public interest. First, Congress has already pronounced that it is in the public's interest to integra te commercially flown UAS's int o the national airspace system, hence the passing of the Refor m Act. Second, Olin conducts rese arch into safe UAS operations every time it flies one of its UAS's. Flight data, visual inspe ctions, recorded observations and flight analyses are compiled a nd analyzed as a part of the rese arch effort to further enhance current safety protocols. Allowi ng 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 agenc ies, 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 s ubstantially furthers the pu blic's interest in ways known and currently unknown. Permitting Olin to immediately fly within th e United States furthers advancements in publicly usable t echnologies 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 cheap ly and quickly available.

Reasons Why Olin’s Exemption Will Not Adversely Affect Safety O r How The Exemption Will Provide a Level of Safety At Least Equal To Exis ting Rule:

Olin’s exemption will not advers ely affect safety. Quite the co ntrary, 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 pr otocols while exploring the advantages and limitations of computer assisted ground station monitoring.

Olin’s UAS's weigh less than 55 pou nds complete with cameras an d 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 whe n they reach 25% battery power.

Olin’s remote control pilots ope rate all Olin UAS's by Visual L ine of Sight.

Olin remote control pilots have a second spotter, plus video an d telemetry backup should they somehow lose sight of the UAS.

Olin’s aircraft are controlle d with unaltered, hobby-grade 2.4G Hz spread-spectrum radios
for control and 900MHz radios fo r telemetry. Both radio system s are common standards used throughout the hobby / amate ur community. The 900MHz radi os are designed and sold by 3DRobotics, makers of the commercial PixHawk autopilot (seen in Figure 3).

Olin staffs each flight with a rem ote control pilot and camera operator and, if the testing team is all-student, a faculty supervisor.

Olin UAS's have GPS flight mode s whereby they hover and then sl owly land if communication with the remote cont rol pilot is lost, battery po wer is below25% or the vehicle leaves the pre-de termined flight area.Olin Way Needham, MA 02492-1200
781-292-2300 www.olin.edu

7 Olin actively analyses electroni c flight data and other sources of information to constantly update and enh ance safety protocols.

Olin only operates in secured ar eas that are strictly controlle d, are away from airports and populated areas and ha ve written permission from t he property owner.

Olin conducts extensive briefi ngs prior to and after each fligh t, during which safety carries primary importance;

Olin always obtains all necessary permissions and permits prio r to operation;

Olin provides a level of safety a t least equal to existing rule s, and in nearly every instance, greater than existing rules.

Summary the FAA may publish i n the Federal Register:

14 .F.R. 21 and 14 C.F.R. 91: Airworthi ness Certificates, Manuals and the Like. 14 C.F.R. 21, Subpart H, entitled Airworthin ess Certificates, sets forth requirements for procurement of necessary airwort hiness certificates in relation to FAR§ 91.203(a)(l). The size, weight and enclosed operati onal area of Olin’s UAS's perm its exemption from Part 21 because Olin UAS's meet an equivalent level of safety pursua nt to Section 3 3 3 of the Reform Act. The FAA is authorized to exempt aircraft from the a irworthiness certificate requirement under both the Act (49 U.S. C. § 44701 (f)) and

A. Section 333 of the Reform Act . Both pieces of legislation permi t the FAA to exempt
UAS's from the airworthiness ce rtificate requirement in conside ration of the weight, size, speed, maneuverability and proxim ity 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 ope ration of an aircraft witho ut an airworthiness certificate. As no such certificate will be applicable in the f orm contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires a n aircraft flight manual in the aircraft. As there are no pilots or passengers, and given t he size of the UAS's, this Reg ulation is inapplicable. An equivalent level of safety will be achieved by maintaining a ma nual at the flight operations center. The FAA has pr eviously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 1016 7, 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 gyro scopes to provide spatial
coordination.

14 C.F.R. § 91.203 (a) and (b) provid es for the carrying of civ il aircraft certifications and registrations. They are inapplicab le for the same reasons descr ibed above. The equivalent level of safety will be achie ved by maintaining such certificat ions and registrations at the Olin research laboratory/ flight operati ons center.

B. 14 C.F.R. § 45.23: Marking of the Air craft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specificatio ns. Olin’s UAS's are, by definition, unmanned. They therefore do not have a cabin, cockp it or pilot station on which to mark certain words or phrases. Further, two-inch lette ring is difficult to place on
such small aircraft. The FAA has previously issued exemptions t o this regulation through Exemptions Nos. 8738,10167, 10167A and 10700.

C. 14 C.F.R. § 61.113: Private Pilo t Privileges and Limitations . Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots a re limited to non-commercial operations. Olin can achieve an equivalent level of saf ety as achieved by current Re gulations because Olin’s UAS's do not carry any pilots or pa ssengers. Further, while he lpful, a pilot license will not ensure remote control piloting skills. Olin’s model aircra ft pilot vetting and training programs (based upon completion of an Academy of Model Aircraft recommended and a self-administered UAS flight tra ining program and internal proc edures) will. Also, the risks attendant to the operation of Olin’s UAS's is far less th an 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 Saf e Altitudes. 14 C. F. R. § 91.1 19 prescribes safe altitudes for the operation of civil aircraf t. It allows Helicopters to b e operated at lower altitudes in
certain conditions. Olin’s UAS's w ill never operate at an altit ude greater than 400 AGL. Olin will, however, operate its UAS's in sectioned off areas wi th security perimeters, providing a level of safety at le ast equivalent to those in rel ation to minimum safe altitudes. Given the size, wei ght, 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, a mongst other things, aircraft owners and operators to "have [the] aircraft inspected a s prescribed in subpart E of th is part and shall betweenOlin 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 pres cribed in part 43 of this chapter ."

These Regulations only apply to air craft with an airworthiness certificate. They will not, therefore, apply to Olin should its requested exemption be gran ted. Even so, Olin
conducts an extensive maintenan ce program that involves regular software updates and constant inspecti on for assessment and replacement/ repair of any damaged hardware. Therefore, an equivale nt level of safety will be achi eved. Olin is using currently manufactured UAS’s for its research which have been p roduced in significant numbers, which also allows Olin t o avail itself of the higher r eliability and expertise of
the vehicle manufacturers whic h will further help in keeping al l vehicles safe.

F. Summary

Olin seeks an exemption from th e 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 comme rcially 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, s earch and rescue. Granting Ol in’s request for exemption will reduce current risk levels and thereby enhance safety.

Further, Olin operates at lower altitudes and in controlled air space. Olin has been analyzing flight data and other information in compiling safety protocols and the implementation of a flight operations manual that exceeds curre ntly accepted means and methods of safe flight for the se vehicles. There are no people on board Olin UAS's and
therefore the likelihood of deat h or serious bodily injury is s ignificantly limited. Olin’s operation of its UAS's, weight ing less than 55 pounds and trave ling at speeds lower than 50 knots, in cordoned off areas will provide at least an equiva lent 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 req uest without delay. The FAA has the authority t o issue the exemption sought by Olin pursuant to the Federal A viation Act, 85 P.L. 726 (1958), as am ended (the "Act").

Sincerely,

Prof. Andrew Bennett Associate Professor of Mechanical Engineering Franklin W. Olin College of Engineering
781-292-2522 Andrew.Bennett@olin.edu