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Thomas D. Conte

435 Bellevue Ct

Allen, TX 75013

Phone: 214 383 1277

tmc705@sbcglobal.net

Airman Certificate Number: 3069778

Academy of Model Aeronautics Number: 125414

My request is for a waiver of the sections identified below in an effort to operate a sUAS for Flight 

Training.

The specific applicable regulations from which relief is required (CFRs); Section of 14 CFR: parts 

21 Subpart H, 27, 45.23(b), 45.27(a), 61.113(a) and (b), 61.133(a),

91.7(a), 91.9(b) (2), 91.109(a), 91.119, 91.151(a), 91.203(a) and (b), 91.225, 91.319(a)

(1), 91.405(a), 91.407(a) (1), 91.409(a) (2), 91.417(a) and (b). Additional regulations may be 

included if the FAA deems it necessary.

Suggested Public Federal Register Summary:

"The petitioner is seeking an exemption to operate a small unmanned aircraft system (sUAS) 

with a maximum weight of five pounds to provide Flight Training and STEM education to High 

School students."

As a current Commercial Pilot and Flight Instructor, I am aware of current regulations 

concerning the National Air Space and how to obtain the most current information like NOTAMs 

and TFRs required for safe flight. This request for an Exemption is to allow a multi-rotor to operate

in the NAS. I’m a Beta tester for the B4UFLY App and on December 21, 2015 I will comply with 

the new registration requirements. 

I have been working for years with local High Schools and Boy Scouts using Radio Control 

aircraft to introduce them to basic aeronautics. Using the miniature aircraft I also introduced the 

Students to STEM subjects’ especially digital electronics, sensors, and programming. Recently, 

some school administrators have express the interest in being able to provide the students the 

opportunity to obtain experience that may result in receiving a license or certification that would 

allow them to start a career right out of high school as an option to pursuing a college degree. 

Working with the students using miniature aircraft, we have been able to encourage some to a point 

where they continued in the aviation field and they have progressed to full-size flight training. There 

is a strong interest in the proposed Drone Operator certificate and as a Ground Instructor, I have 

begun to create a curriculum in response to their interest in sUAS operations.

I realized that a training aircraft was needed that would give the students hands-on 

experience and built the multi-rotor to experiment with and fly.

The multi-rotor miniature aircraft in made with materials and equipment that are common in 

the hobby community and that have a good reliability record (see included specifications, page 3). 

The Radio Control transmitter and receiver are off the shelf units that are FCC approved. Being light 

weight and intentionally designed to have limited performance and range it shouldn’t pose a threat to 

people that are not directly involved in its operation. Since this multi-rotor is to be used as an 
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introductory training device to potential full-size pilots, pre-flight briefings and checklists will be 

created and used in its operation.

The multi-rotor itself is designed so components can be individually tested. The Flight 

Controller has open-sourced software so students can gain experience with writing code. The multirotor itself is very simple and easy to repair or duplicated. Having a multi-rotor available for the 

Students to fly makes the classroom lessons a reality.

Because of the relatively small size of the sUAS, the experience of the Student pilots will 

receive, and the educational value; this request appears to be well suited for approval using the 

criteria outlined in Section 333 of the FAA Modernization and Reform Act of 2012 and will move

safe flight operations forward in accordance with the intent of Section 333.

The proposed operations:

While I have tried using the local model aircraft flying fields, they are not close to the 

schools or convenient for the Students during the school day. Being able to use the School’s grounds

will make operations easier. While flying at the Schools will not interfere with full-size aircraft, I 

believe that obtaining an Exemption will give me the flexibility to train Students at their schools or 

at other local fields. I would also like to be able to satisfy the local officials concerns that the training 

is being done under the auspicious of the Federal Aviation rules and regulations.

Flight operations will only begin after getting the School’s Administrators permission. Flying 

the sUAS would be part of the lesson plan and a briefing would have been done before the flight. 

Only the minimum number of people will be allowed in the flying area. The Students, Instructors, 

and persons that have asked to observe and have been briefed on what to expect will be allowed. The 

Flight Controller self-fly feature has the option to be shut down during flight in the case of a 

malfunction and the sUAS can be hand flown or automatically set to return to its original location of 

take-off. Just like a full-size aircraft, the Student will have their own controls with the Instructor 

having a separate unit that can over-ride the Student’s if needed. The Instructors will be FAA 

licensed pilots as well as being proficient in flying model aircraft.

In regards to allowing the Students to change the Flight Controller’s software. A simulation 

of the software modification can be run on a computer to see what effect it will have before an actual

flight, changes are not permanent and the original programming can be re-installed if a problem is 

discovered. A functional test flight will be accomplish by an Instructor before a Student would be 

allowed to fly it.

Keeping a detail sUAS flight log that would include where, who, condition of weather, any 

software change made, flight time and what battery capacity used and will provide details of the 

flight and be part of the data gathering process. Each student will have their own logbook and record

their flight time in accordance to Part 61.51 format. A separate maintenance log for the multi-rotor 

will be kept to record all repairs or modifications and help in calculating operating cost.
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Thomas D. Conte

435 Bellevue Ct

Allen, TX 75013

Phone: 214 383 1277

tmc705@sbcglobal.net

Airman Certificate Number: 3069778

Academy of Model Aeronautics Number: 125414