January 17, 2016 

U.S. Department of Transportation 

Docket Operations

1200 New Jersey Ave., SE

Washington, DC 20590

Dear Sir/Madam 

Pursuant to Section 333 of Public Law 112-95, Waterlust LLC hereby 

applies for authorization to conduct commercial unmanned aerial 

systems (UAS) operations within the United States National Airspace 

(NAS) for the purpose of Education, Research, UAS platform 

development, aerial photography and videography.

Federal Register Summary 

Pursuant to 14 CFR §11.81, the following summary is provided for 

publication in the Federal Register if needed. 

Waterlust LLC. seeks exemption from 14 CFR Part 21, Subpart H; 14 

CFR Part 27; 14 CFR 45.23(b); 14 CFR 61.113(a)(b); 14 CFR 91.7(a); 

14 CFR 91.9(b)(2)(c); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 

91.119; 14 CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a)(b); 14 

CFR 91.405(a); 14 CFR 91.407(a)(1); CFR 91.409(a)(1) and (a)(2); 14 

CFR 91.417(a)(b) to allow commercial employment of Unmanned 

Aerial Systems (UAS) in support of education, research, UAS platform 

development, aerial photography and videography in the field of 

marine science. This exemption will enhance safety by reducing risk to 

the general public and property owners from the substantial hazards 

associated with performing equivalent work with conventional aircraft 

and rotorcraft.

Patrick Rynne, PhD 

617-529-8165

patrick@waterlust.org

3203 Mary Street 

Apt. 3

Miami, FL

33133

WATERLUST LLC
The Name and address of the applicant/operator is: 

Dr. Patrick F. Rynne 

Waterlust LLC 

3203 Mary Street, Apt. 3 

Miami, FL, 33133 

patrick@waterlust.org

617-529-8165
Introduction and Interest of the Petitioner 

The use of small unmanned aerial systems (sUAS) in documenting 

marine science through film and photography has enabled the growth 

of scientific communication and outreach in this field. These devices 

are used regularly to reduce costs and increase safety while 

documenting field research, while also providing researchers imagery 

above a study site that can be used to remotely measure physical 

characteristics of a system (e.g. topography, bathymetry) and 

kinematic behavior of water (e.g. detection of wave breaking, flow 

velocity, dispersion and advection of material) [1]. sUAS provide 

several benefits as compared to conventional aerial platform methods 

including reduced costs, reduced risk to human pilots and their 

passengers, reduced wildlife disturbance, and improved observations. 

Waterlust LLC is developing a UAS program to 1) support ocean 

scientists who seek to use sUAS in their research, 2) to document 

marine science and ocean engineering topics through film and 

photography 3) to conduct sUAS-based research in the field of marine 

science and ocean engineering, 4) to further the development of 

sUAS platforms for use in the marine environment. The nature of this 

work requires sUAS operations predominantly in remote coastal 

areas, away from human activities and often over water. 
Overview of Proposed UAS 

Qualification for Approval Under Section 333 of the Reform Act 

The proposed operations would permit the use of small Unmanned 

Aerial Systems (UAS) in airspace that is: (1) limited; (2) predetermined; 

(3) away from populated areas; (4) would provide an increased level of 

safety as compared to existing fixed or rotor wing aircraft when used 

for the same purpose. 

The UAS planned to be operated are rotorcraft, each weighing less 

than 10 lbs, and always less than 55 lbs., including payload. They 

would operate, under normal conditions, at a speed of no more than 

40 knots. Operations will be performed by a qualified UAS Pilot in 

Command (PIC), as outlined below. 

3DR X8 3DR Solo

Aircraft Type Multirotor (8) Multirotor (4)

Aircraft Weight 2.56 lbs. (5.6 kg) 3.3 lbs. (1.5 kg)

Max Takeoff Weight 7.7 lbs. (3.5 kg) 3.9 lbs. (1.8 kg) 

Dimensions 13.7 in x 20.1 in x 11.8 in 

(35 cm x 51 cm x 30 cm)

10 in x 18 in x 9.2 in 

(25 cm x 46 cm 23 cm)

Max Flight Time 15 minutes 20 minutes

Max Airspeed 55 mph (89 km/h) 55 mph (89 km/h)

Propulsion 800 kV brushless motors 880 kV brushless motors

Power Source Lithium polymer 6000 

mAh 14.8 Vdc

Lithium polymer 5200 

mAh 14.8 Vdc

Payload Digital Compact Camera Digital Compact Camera

Airframe Material Aluminium Injected Molded Plastic
1. Operations authorized by this grant of exemption are limited to 

the following craft: 3DR X8, 3DR Solo.

2. UA (aircraft and payload) will weigh less than 55lbs.

3. UA will be operated at altitudes not greater than 400 feet AGL 

Altitudes reported to ATC will be in feet AGL.

4. UA will be flown at ground speeds not greater than 40 knots. 

5. The UAS PIC will hold either an airline transport, commercial, 

private, recreational or sport pilot certificate. The PIC will also 

hold a current FAA airman medical certificate or a valid U.S 

driver’s license issued by a state, the District of Columbia, 

Puerto Rico, a territory, a possession, or the Federal 	 	

government. The PIC will also meet the recent flight 	 	

experience requirement stated in 14 CFR § 61.57 and flight 

review requirements stated in 14 CFR § 61.56. 

6. In addition to holding an FAA issued airman certificate, UAS 

PIC will also complete UAS training from Waterlust LLC and 

the UAS manufacturer (3D Robotics Inc). This training will 

include detailed review of the operating capabilities of the X8 

and Solo UAS and their subsystems. Each PIC will train in a 

controlled environment to develop the abilities required for the 

operations described under this exemption. PIC qualification 

will have a currency requirement of at least ten take-offs and 

landings within the preceding 90 days. PIC qualification flight 

hours will be logged in a manner consistent with 14 CFR § 

61.51. 

7. UA will not be operated within 5 nautical miles (NM) of an 

airport reference point (ARP). 
8. UAS flights will operate within visibility and cloud clearance 

requirements equivalent to Visual Flight Rules (VFR). 

9. UAS operations will not be conducted during night, as defined 

within 14 CFR § 1.1. 

10. UA flights over land will not be operated by the PIC from any 

moving vehicle or device. UA flights conducted entirely over 

water may be operated from a suitable vessel. 

11. UA will not be operated from a raised platform. 

12. The UA will remain clear of and yield right of way to manned 

aviation operations.

13. UA will be operated within visual line of sight (VLOS) of the PIC 

at all times. The PIC will use human vision unaided by device 

other than corrective lenses as specified on PIC’s FAA medical 

certificate or drivers license.

14. UAS operations will employ a visual observer (VO). The VO 

may be used to satisfy the VLOS requirement as long as the 

PIC maintains VLOS capability. The VO and PIC must be able 

to communicate verbally for the duration of the flight. Electronic 

messaging or texting is not allowed during flight operations.

15. The VO will perform no duties other than assisting the PIC see 

and avoid other aircraft, obstacles, persons or property.

16. UAS will be equipped with an autopilot system. The UAS will 

utilize GPS navigation, failsafe’s, return-to-home (RTH) and 

flight abort safety features.
17. Prior to each flight the PIC will inspect the UAS to ensure it is in 

a condition for safe flight. Checklists developed from 

manufacturer operating documents will be the basis for this 

inspection. If the inspection reveals a condition that affects safe 

operation of the UAS, the aircraft is prohibited from operating 

until necessary maintenance has been performed and the UAS 

is found to be in a safe condition for flight. The Ground Control 

Station must be included in the preflight inspection. 

18. All UAS operations will be conducted over remote and sparsely 

populated property or over open waters. Permission for flight 

will be obtained in advance from property owners or controlling 

agency. A Ground Station will be connected, by radio 	 	

communication, to the UAS during the entire flight, which will 

give the PIC flight information such as GPS Position, Altitude, 

Air speed, Battery Remaining, and other telemetry information. 

19. Flight boundaries will be established for each flight and such 

boundaries will be designed such that the UA will pass no 

closer than 500 feet from nonparticipating persons, vehicles or 

structures. 

20. If the UAS loses communications or loses GPS signal, the UA 

will return to a predetermined location within the established 

flight boundary and land or be recovered in accordance with 

manufacturer operations documents. 

21. The PIC will abort any flight in the event of unpredicted 		

obstacles, occurrence of adverse weather or loss of UAS flight 

control capability in accordance with manufacturer operations 

documents. 

22. The PIC is prohibited from beginning a flight unless 	 	

(considering wind and forecast conditions) there is enough 

power to fly the planned route to the intended landing point 

and land the UAS with 25% of battery capacity remaining. 
23. Documents required by 14 CFR § 91.9 and 91.203 will be 

available to the PIC at the Ground Control Station of the UAS 

whenever the aircraft is operating. These documents will be 

made available to the Administrator or any law enforcement 

official upon request. 

24. Before conducting flight operations, the radio frequency 

spectrum used for operation and control of the UA must 

comply with Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 

25. A Flight Operations and Maintenance Log will be maintained for 

each UAS. Cumulative flight hours, maintenance activities, 

repairs, alterations and inspections will be noted. 

26. Any UAS maintenance or alterations that affect UAS operation 

or flight characteristics, e.g. replacement of a flight critical 

component, must undergo a functional test flight. The PIC who 

conducts the functional test flight must make an entry in the 

Flight Operations and Maintenance Log. 

Specific Sections of 14 CFR from which Petitioner seeks 

Exemption or Relief

14 CFR Part 21, Subpart H – Airworthiness Certificates and 14 

CFR § 91.203(a)(1) 

The FAA has stated that no exemption is needed from this section if a 

finding is made under Part 11 and Section 333 of the Reform Act that 

the UAS selected provides an equivalent level of safety when 

compared to civil aircraft normally used for the same application. The 

petitioner submits that given the small size of the UAS, the limited 

operating areas and procedures defined within the training and 
operations section of the petition, an equivalent level of safety is 

obtained and exemption is not required (see Grant of Exemption to 

Astraeus Aerial, Docket No. FAA-2014-0352). If however, the FAA 

determines that there are some characteristics of the chosen UAS 

that fail to meet the requirements of the Reform Act, an exemption is 

requested. 

14 CFR Part 27 – Airworthiness Standards: Normal Category 

Rotorcraft 

14 CFR Part 27 sets forth the procedural requirements for 

airworthiness certification of normal category rotorcraft. To the extent 

petitioner’s UAS would otherwise require certification under Part 27, 

petitioner seeks exemption for the same reasons identified in the 

request for exemption from 14 CFR Part 21, Subpart H. 

14 CFR § 45.23 (a)(b) and 91.9 (c) – Marking of the Aircraft 

Regulation 45.23 provides: (a) Each operator of an aircraft must 

display on that aircraft marks consisting of the Roman capital letter 

“N” (denoting United States registration) followed by the registration 

number of the aircraft. Each suffix letter used in the marks displayed 

must also be a Roman capital letter. (b) When marks include only the 

Roman capital letter “N” and the registration number is displayed on 

limited, restricted or light-sport category aircraft or experimental or 

provisionally certificated aircraft, the operator must also display on 

that aircraft near each entrance to the cabin, cockpit, or pilot station, 

in letters not less than 2 inches nor more than 6 inches high, the 

words “limited,” “restricted,” “light-sport,” “experimental,” or 

“provisional,” as applicable.

Regulation 91.9 (c) provides: No person may operate a U.S.-

registered civil aircraft unless that aircraft is identified in accordance 

with part 45 of this chapter. 
The UAS has no entrance to the cabin, cockpit or pilot station on 

which markings can be placed. Given the small size of the UAS, twoinch lettering will not be possible. In a previous Grant of Exemption, 

the FAA determined that exemption from these requirements was 

warranted provided that the aircraft “have identification (N-Number) 

markings in accordance with 14 CFR Part 45, Subpart C if the 

markings are as large as practicable.” The petitioner additionally 

proposes to place all required markings, placards, flight envelope 

restrictions, cautionary notices in an easily visible location at the UAS 

Ground Control Station. The FAA has issued several exemptions to 

this regulation: see Exemptions Nos. 8738, 10167, 10167A and 

10700. 

14 CFR § 91.9(b)(2) – Aircraft Flight Manual in the Aircraft 

Regulation 91.9 stipulates (b) No person may operate a U.S.-

registered civil aircraft— (2) For which an Airplane or Rotorcraft Flight 

Manual is not required by §21.5 of this chapter, unless there is 

available in the aircraft a current approved Airplane or Rotorcraft Flight 

Manual, approved manual material, markings, and placards, or any 

combination thereof. 

Given the size of the UAS, they have no place or ability to carry a flight 

manual aboard the aircraft. An equivalent level of safety will be 

achieved by keeping the flight manual at the Ground Control Station 

where the pilot operating the UAS will have immediate access to it. 

The FAA has issued several exemptions to this regulation: see 

Exemptions Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 10167, 

10602, 32827 and 10700. 

14 CFR § 61.113 (a)(b) and 61.133(a)(i)(ii) – Private and 

Commercial Pilot Privilege and Limitations 

Regulation 61.113 stipulates (a) Except as provided in paragraphs (b) 

through (h) of this section, no person who holds a private pilot 

certificate may act as pilot in command of an aircraft that is carrying 
passengers or property for compensation or hire; nor may that 

person, for compensation or hire, act as pilot in command of an 

aircraft. 

(b) A private pilot may, for compensation or hire, act as pilot in 

command of an aircraft in connection with any business or 

employment if: (1) The flight is only incidental to that business or 

employment; and (2) The aircraft does not carry passengers or 

property for compensation or hire. 

Regulation 61.133 stipulates (a) Privileges—(1) General. A person who 

holds a commercial pilot certificate may act as pilot in command of an 

aircraft— (i) Carrying persons or property for compensation or hire, 

provided the person is qualified in accordance with this part and with 

the applicable parts of this chapter that apply to the operation; and (ii) 

For compensation or hire, provided the person is qualified in 

accordance with this part and with the applicable parts of this chapter 

that apply to the operation. 

Unlike a conventional aircraft that carry pilot, passengers and cargo, 

the proposed UAS are remotely controlled and carry no persons or 

cargo. The UAS are capable of a high degree of flight automation and 

employ technical capabilities that limit the potential for operation in an 

unintended manner. It is the petitioner’s belief that given the size, 

weight, speed, operating environment and operating capabilities of 

the UAS, an equivalent level of safety may be obtained by stipulating 

the UAS PIC must hold either an airline transport, commercial, private, 

recreational, or sport pilot certificate. The PIC must also hold a current 

FAA airman medical certificate or a valid U.S. driver’s license issued by 

a state, the District of Colombia, Puerto Rico, a territory, a possession, 

or the Federal government. The PIC must also meet the flight review 

requirements specified in 

14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her 

pilot certificate. The FAA has issued several exemptions to this 

regulation: see Exemptions Nos. 11284, 11281, 11282 and 11296. 
14 CFR § 91.7(a) – Civil Aircraft Airworthiness 

Regulation 91.7 stipulates (a) No person may operate a civil aircraft 

unless it is in an airworthy condition. 

Should this exemption be granted allowing commercial operation of 

UAS without an airworthiness certificate, no FAA regulatory standard 

will exist for airworthiness of the UAS. An equivalent level of safety will 

be obtained by ensuring compliance with UAS operator and 

maintenance manuals and safety checklists prior to each flight. 

14 CFR § 91.121 – Altimeter Settings 

Regulation 91.121 requires that (a) Each person operating an aircraft 

shall maintain the cruising altitude or flight level of that aircraft, as the 

case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to— (i) The current reported altimeter 

setting of a station along the route and within 100 nautical miles of the 

aircraft; (ii) If there is no station within the area prescribed in paragraph 

(a)(1)(i) of this section, the current reported altimeter setting of an 

appropriate available station; or (iii) In the case of an aircraft not 

equipped with a radio, the elevation of the departure airport or an 

appropriate altimeter setting available before departure. 

Conventional aircraft are provided altitude data by a barometric 

altimeter that is most commonly set to a local barometric pressure 

and therefore reports altitude relative to MSL (Mean Sea Level). UAS 

operations are restricted to altitudes no greater than 200 feet AGL 

(Above Ground Level). For those UAS with a barometric sensor, 

greater utility and an equivalent level of safety will be obtained by 

setting the altimeter to read “zero altitude” when the UAS is on the 

ground prior to takeoff thus providing an AGL altitude readout. If no 

barometric sensor is aboard the UAS, a GPS derived altitude similarly 

set to zero at the takeoff point will provide an equivalent level of safety. 

The FAA has issued several exemptions to this regulation: see 

Exemptions Nos. 11066, 11065, 11062 and 11063. 
14 CFR § 91.151 – Fuel Requirements for Flight in VFR 

Conditions 

Regulation 91.151 stipulates that (a) No person may begin a flight in 

an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point 

of intended landing and, assuming normal cruising speed—(1) During 

the day, to fly after that for at least 30 minutes; or (2) At night, to fly 

after that for at least 45 minutes. (b) No person may begin a flight in a 

rotorcraft under VFR conditions unless (considering wind and forecast 

weather conditions) 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 20 minutes. 

This regulation is written based on the capabilities of traditional civil 

aircraft which typically have flight times with full fuel of several hours. 

For the majority of UAS which have flight times of an hour, or much 

less, this regulation would effectively deny an ability for the UAS to 

operate. The petitioner submits that an equivalent level of safety will 

be obtained by requiring that no UAS flight will begin unless 

(considering wind and forecast conditions) there is enough fuel 

(battery) to fly the planned route to the first point of intended landing 

and land with 25% of battery capacity in reserve. This restriction 

would be more than adequate to return the sUAS to its planned 

landing zone from anywhere in its limited operating area. 

The FAA has issued several exemptions to this regulation: see 

Exemptions Nos. 2689F, 5745, 10673 and 10808. 

14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b) – 

Maintenance Inspections 

Regulation 91.405(a) requires that an aircraft operator or owner “shall 

have that aircraft inspected as prescribed in Subpart E of this Part, 

and shall between required inspections, except as provided in 

paragraph (c) of this section, have discrepancies repaired as 
prescribed in Part 43 of this chapter...” Regulation 91.407(a)(1) 

similarly makes reference to requirements in Part 43. Regulation 

91.409(a)(2) requires an annual inspection for the issuance of an 

airworthiness certificate. Regulation 91.417(a) and (b) requires the 

owner or operator to keep records showing certain maintenance work 

that has been accomplished by certificated mechanics, under Part 43, 

or licensed pilots and records of approval of the aircraft for return to 

service. 

Exemption from these regulations is needed because Part 43 and 

these sections apply only to aircraft with an airworthiness certificate. 

An equivalent level of safety will be obtained by requirement that each 

UAS will have a flight and maintenance log. Maintenance and 

inspections will be accomplished in accordance with manufacturer 

recommendations. The FAA has issued several exemptions to this 

regulation: see Exemptions Nos. 11066, 11062, 11067A and 11065. 

14 CFR § 91.103 – Preflight Action 

Regulation 91.103 stipulates Each pilot in command shall, before 

beginning a flight, become familiar with all available information 

concerning that flight. This information must include—(a) For a flight 

under IFR or a flight not in the vicinity of an airport, weather reports 

and forecasts, fuel requirements, alternatives available if the planned 

flight cannot be completed, and any known traffic delays of which the 

pilot in command has been advised by ATC; (b) For any flight, runway 

lengths at airports of intended use, and the following takeoff and 

landing distance information: (1) For civil aircraft for which an 

approved Airplane or Rotorcraft Flight Manual containing takeoff and 

landing distance data is required, the takeoff and landing distance 

data contained therein; and 

(2) For civil aircraft other than those specified in paragraph (b)(1) of this 

section, other reliable information appropriate to the aircraft, relating to 

aircraft performance under expected values of airport elevation and 

runway slope, aircraft gross weight, and wind and temperature. 
The petitioner seeks exemption to the extent that an FAA-approved 

Flight Manual is required. An equivalent level of safety will be provided 

by following the Operations Manual provided by the manufacturer. 

Additionally, the PIC will conduct preflight actions, to include 

performing all required checklists, reviewing weather, flight 

requirements, battery charge, landing and takeoff distance, aircraft 

performance data, and contingency landing areas, before initiation of 

flight. 

14 CFR § 91.109 – Flight Instruction 

Regulation 91.109 stipulates, in part, that (a) No person may operate 

a civil aircraft (except a manned free balloon) that is being used for 

flight instruction unless that aircraft has fully functioning dual controls. 

UAS by their design do not have fully functional dual controls. Flight 

control is accomplished through the use of a control interface that 

communicates with the aircraft via radio. Given the size, speed and 

limited operational parameters of the UAS, an equivalent level of safe 

training can be performed without dual controls. The FAA has issued 

several exemptions to this regulation: see Exemptions Nos. 11066, 

11062, 11067A and 11065. 

14 CFR § 91.119 – Minimum Safe Altitudes 

Regulation 91.119 stipulates, in part, that, Except when necessary for 

takeoff or landing, no person may operate an aircraft below the 

following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency 

landing without undue hazard to persons or property on the surface. 

(b) Over congested areas. Over any congested area of a city, town, or 

settlement, or over any open air assembly of persons, an altitude of 

1,000 feet above the highest obstacle within a horizontal radius of 

2,000 feet of the aircraft. (c) Over other than congested areas. An 

altitude of 500 feet above the surface, except over open water or 

sparsely populated areas. In those cases, the aircraft may not be 
operated closer than 500 feet to any person, vessel, vehicle, or 

structure. 

An exemption to 91.119(c) is required because UAS operations will be 

conducted at altitudes no greater than 200 feet above the surface. 

The size, speed, weight and limited operational parameters of the 

UAS allow for an equivalent level of safety. 

Why Granting this Petition is in the Public Interest 

The requested exemption would authorize Waterlust LLC to perform 

commercial operations with sUAS that will provide significant benefits 

to the public interest. These benefits include: 

1. The commercial use of sUAS to document marine 

	 	 research through film and photography in an effort to 

	 	 increase public awareness of global environmental 

	 	 concerns and increase public engagement [2]. The 

	 	 ability to improve society through publicly funded 

	 	 scientific research relies on the researchers ability to 

	 	 communicate their findings to the general public. The 

	 	 use of sUAS enables the documentation of work in the 

	 	 marine environment for educational purposes that 

	 	 would otherwise not be accessible. 

2. The commercial use of sUAS to perform marine science 

	 	 and engineering research activities at Waterlust LLC in 

	 	 support of governmental entities, private research 

	 	 institutions, scientific and engineering studies are all 

	 	 critical to the well-being of the general public. These 
	 	 include for example: rapid bathymetric mapping of the 

	 	 coastal environment, measurement of effluent 	 	

	 	 boundaries near tidal inlets, and determination of spatial 

	 	 and temporal mixing scales from tracer studies using 

	 	 aerial orthophotos [1]. 

3. The use of sUAS will decrease congestion in the 	

	 	 National Airspace System along with reducing the noise 

	 	 and air pollution generated during traditional manned 

	 	 aircraft flight operations. 

4. The use of sUAS to collect scientific data reduces the 

	 	 risk of personnel that would otherwise use conventional 

	 	 methods. For example, bathymetric surveying of the 

	 	 nearshore environment including the surf zone requires 

	 	 a manned aerial vehicle, terrestrial vehicle or walking 

	 	 surveyor to transit across unstable/unsafe terrain. 

5. Operation of sUAS will substantially reduce the risk to 

	 	 life and property in the air, and on the ground, as 

	 	 compared to conventional manned aircraft flight 		

	 	 operations required to accomplish the same missions. 

Approval of this exemption would thereby enhance safety and fulfill 

the Secretary of Transportation’s responsibilities under Section 333(c) 

of the Reform Act to “establish requirements for the safe operation of 

such aircraft systems in the national airspace system.” 

Summary of Regulations from which Petitioner Seeks 

Exemption or Relief 
14 CFR Part 21, Subpart H 14 CFR Part 27

14 CFR 45.23(b)

14 CFR 61.113(a)(b)

14 CFR 91.7(a)

14 CFR 91.9(b)(2)(c)

14 CFR 91.103

14 CFR 91.109(a)

14 CFR 91.119

14 CFR 91.121

14 CFR 91.151(a)

14 CFR 91.203(a)(b)

14 CFR 91.405(a)

14 CFR 91.407(a)(1)

CFR 91.409(a)(1) and (a)(2) 14 CFR 91.417(a)(b) 

References 

[1] Ronald L. Brouwer, Matthieu A. de Schipper, Patrick F. Rynne, 

Fiona J. Graham, Ad J. H. M. Reniers, and Jamie H. MacMahan, 

2015: Surfzone Monitoring Using Rotary Wing Unmanned Aerial 

Vehicles. J. Atmos. Oceanic Technol., 32, 855–863. 

[2] Example of how sUAS contributes to outreach, scientific 

communication and broader impacts. 

http://www.rsmas.miami.edu/blog/2015/04/21/carthe-waterlustteam-wins-top-prize-in-video-challenge/