### June 26, 2015
Docket Operations Ohio/Indiana UAS Center & Test Complex 1 41 70 Alliu m Ct., Springfield , OH 45505 937-497-6739



### U.S. Department of Transportation West Building Ground Floor, Room Wl2-140 1200 New Jersey Avenue, S.E. Washington, D.C. 20590

### .··,**( ·.r** 



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### Re: Exemption Request under Section 333 of the FAA Modernization and Reform Act of2012
Dear Sir or Madam:
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, the Ohio/Indiana Unmanned Aircraft Systems Center and Test Complex (UASC&TC) , seeks an exemption from the Federal Aviation Regulations (FARs) listed below and detailed in Appendix A to allow for commercial operations of small unmanned aircraft systems (sUAS).

14 CFR §Part 21 14 CFR §Part 61.113 (a) & 

### (b) 14 CFR §Part 91.7 (a) 14 CFR §Part 91.9 (b) (2) 14 CFR § Pru191.103 14 CFR §Part 91.109 14 CFR § 

### Part 91.119 14 CFR §Part 91.121 14 CFR §Part 91.151 14 CFR §Part 91.203 (a) & (b) 

### 14 CFR §Part 91.405 (a) & (b) 14 CFR § Part 91.407 (a) (1) 14 CFR §Part 91.409 (a) (2) 14 CFR §Part 91.417 (a) & 

### (b)

The UAS C&TC, a government entity operating within the Ohio Department of Transportation , coordinates, facilitates and s upports state agencies and universities with their sUAS programs and operations. This exemption will allow the UA SC&TC to safely operate sUAS under controlled conditions in the National Airspace System (NAS) for the purposes of acquiring data for precision agriculture , education, environmental, wildlife and forestry monitoring, infrastructure inspection, survey and mapping , and research and development. The proposed operations would permit the use of sUAS under controlled conditions inOhio/Indiana UAS Center &Test Complex 1 4170 Allium Ct ., Springfield, OH 45505 937-497-6739 accomplish the same purpose. The FAA can be assured that the proposed U AS
o perations wil l be conducted at an equivalent or greater level of safety.
The name and address of the petitioner is:
Ohio/I ndiana UAS Center & Test Comple x ATTN: Richard Honneywell, Exec utive Director Phon e: 937 716-0944 Emai I: Richard

. honneywell@dot.ohio.gov Address: 4170 Allium Court, Springfield , Ohio 45505
The UASC&TC proposes to use the following sUAS p latfo rms for operations under this r eque st :
1. SenseFly eBee 2. Event 38 U nmanned Systems Inc., E3 84 UA S 3. Al t avian Nova F6500 4. Peregrine UAS 5. DJIPhantom 6

. MLB Bat-3 7

. SenseFly Swinglet

Th e manu fact urer instruction s will be used in conjunction with the UASC&TC's Flight Operations Manua l to ensure that the sUAS platforms are operated safely. Eac h of these platforms w e igh les s than 55 lbs, including energy sources and eq uipment. Manufacturer-provided manuals and checklists are enclosed with thi s request. Each UAS consists of a lightweight battery powered aircraft, a PC-based ground control station, and associated communications equipment. The a ircraft carries an onboard gee
-referenced camera that allows it to conduct precision photogrammetry a 

### t the resolutions appropriate for use by each fu nctional area. By approving these exemptions , the FAA will create benefits fo r agriculture, education , research and the environment which are ultimately in the public's interest.

In accordance with the FAAs UAS Integration office ' s g uidance. each of these sUASs will be registered with the FAA. Prior to any UAS operation , the PIC will pe rfo rm the requirements established in the UASC &TC Flight Operations Manual to ensure a NOTAM i s properly filed , the weather excee ds all minimum conditions , all pre-flight checks are complete and that UAS performance is satisfactory fo r flight in th e NAS.
Below is a s ummary of operational limitation s and conditions that will en sure we operate at an equivalent or higher level of s a fe ty for each regulation requiring an exemption:

1. The UASC &TC will obtain an Air Traffic Organization (ATO) issued Certificate o fOhio/Indiana UAS Center & Test Comp lex 1 4170 Allium Ct ., Springfield, OH 45505 937-497
-6739


### 1. The UASC&TC will obtain an Air Traffic Organization (ATO) issued Certificate of Authorization (COA) prior to conducting any VAS operations grant of exemption. 2. All UAS operations will be conducted in accordance with the parameters prescribed in the approved COA. 3

. The sUAS will weigh less than 55 lbs including energy sources and equipment. 4. The sUAS will be flown at speeds not to exceed 50 knots. 5. Flights will be flown at an altitude of no more than 400 feet AGL. 6. sUAS operations will only be conducted during daylight hours under VFR conditions. 7. The PIC will possess at least a private pilot certificate and have a current third

-class medical certificate. The PIC will also meet the flight review requirements specified in 14 CFR 61.56 in an aircraft in which the PIC is rated on his/her pilot certificate. 8. The VAS will be operated within visual line of s ight (VLOS) o f the PIC at all times. 9. The s UAS will not be operated less than 500 feet below or less than 2 , 000 fee t horizonta lly from a cloud or when visibility is less than 3 statute miles from the PIC. 10. All o perations will util ize a visual observer (VO) who will maintain verbal communication with the PIC at all times. 11. The PIC will operate the sUAS from a stationary position and not from a moving device or vehicle. 12. The PIC will ensure that the sUAS remains clear and yield the right of way to all manned operations and activities. 13.Flights will be conducted at a lateral d i stance of at least 100 feet away from inhabited structures, buildings, vehicles , vessels , and any people not associated with the UAS operation. 14.Prior to each flight, the PIC will inspect the UAS to ensure that it is airworthy to operate safely in the NAS. 15. The UASC&TC will follow each manufacturer's sUAS maintenance, overhaul, replacement, inspection and life limit requirements. 16. Maximum total flight time for each operational flight will be limited to the amount of time the UAS can be flown and still maintain reserve battery power or fuel quantity of no Jess than 25%. 17.All documents required by 14 C.F.R sections 91.9 and 91.203 will be a vailable to the PIC at the sUAS ground station any time the sUAS is operating. 18

. Any incident, accident or UAS operation that exceeds the lateral or vertical boundaries of the operational area as defined by the approved COA, will be reported to the FAA's UAS Integration Office (AFS

- 80 ) within 24 hours. Accidents will be reported to the National Transportation Safety Board (NTSB) in accordance with the NTSB guidance. ln addition, UAS operations will not be conducted until the incident. accident or transgression isOhio/Indiana UAS Center & Test Comp l ex 1 4170 Allium Ct ., Springfield, OH 45505 937-497-6739


### reviewed by AFS

- 80 and AFS-80 authorizes the UASC&TC to resume UAS operations.
We submit that the combination of the sUAS's light weight, their demonstrated safe fl ight performance, a fully qualified flight crew and strict operation under the guidelines established in 

### FSIMS 8900

. 1, Volume 16, should allow the FAA to have confidence that our sUAS operations will demonstrate an equivalent or greater level of safety of manned aircraft performing the same mission.
Please do not hesitate to contact us ifyou require any additional information or clarification. Sincerely,

Richard G. Honneywell Executive Director Appendices: A. Exemption Request and Equivalent Level of Safety B. sUAS Operators ManualsOhio/Ind i ana UAS Center & Test Complex 

# 1 4170 Allium Ct

. , Springfield, OH 45505 937-497-6739**,.',**

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I • Appendix A 

### EXEMPTION REQUESTS AND E QUIVALENT LEVEL OF SAFETY

The Ohio/Indiana Unmanned Aircraft Systems Center and Test Complex requests an exemption f rom the following regulations:
14 CFR Pa rt 21, S ub pa rt H : Airworthin ess Ce rtifi cates 14 C F R § 91 .203(a) (1) Subpart H, establishes the procedural requirements as required by 14 CFR 

### § 91.203 (a) (1)

. Given the size and limited operating area associated with the sUAS platforms to be used by the UASC&TC , an exemption from Patt 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 ofthe FMRA. The Federal Aviation Act (49 U.S.C. 

### § 4470l(f)) and Section 333 of the FMRA both authorize the FAA to exempt aircraft from the requirement of airworthiness certificate upon consideration of the size, weight, speed, operational capability and proximity to airports and popul ated areas of the particular sUASs. An analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in a restricted environment and under the conditions proposed by the UASC&TC will be at least as safe as or safer than conventional aircraft operating with an airworthiness certificate without the restrictions and conditions proposed. The sUAS platforms to be operated by the UASC&TC under this exemption all weigh less than 55 pounds. The p latforms carry no personnel or explosive materials and will operate exclusively within the operations area defined in an approved COA. O perations under this exemption will be ti ghtly controlled and monitored by the PIC. The FAA will have advance notice of all of the se sUAS operations
. These safety enhanceme nts provi de a greater degree of safety to the public and property owne rs than conventional operations conducted with airworthiness certi ficates under 14 CFR Part 21, Subpart 

### H.

14 CFR § 6 1.113 (a ) & ( b) : Private Pilot Privileges and Li mitations : Pilot in Comm and Part 61.113 (a) & (b) limits private pi lot privileges to non
-commercial operations. Unlike a conventi onal aircraft that carries a pilot, passengers or cargo, the sUAS is remotely controlled and carries no passengers or property. All s UAS flights will be plan ned and coordinated in advance and the operations area will be co ntrolled. The level of safety provided by t he requirements in t h e UASC&TC's Flight Operations Manual and the Manufacturer Instructions exceeds that pro vided by
an indiv idual holding a commercial pilot's certificate operating a conventional a ircraft. Because the sUAS carries no pilot or passengers , the proposed operati ons can achieve the equivalent leve l of safety ofcurrent operations by requiring the PlC to have a private pilot 's certificate rather than a commercial pilot's ce t tificate to operate the sUAS.

14 CFR § 91.7 (a): Civil Aircraft Airworthin ess This r egulati on requ ires that no person may operate a civil aircraft un l ess it is in an airworthy condi tion. As there will be no airworthiness certificate issued for the sUAS , should this exemption be granted, as no FAA regulatory standar d exists for determ i n ing sU AS ai r worth iness. An equivalent level of safety will be provided by the small size of the sUAS and the requirements contained in the UASC&TCs Flight Operations Manual and Manufacturer Instructions fo r maintenance and use of safety checklists prior to flight

. The UASC&TC w ill ensure that the s UAS is in an airworthy condition prior to each flight based on compliance with the specifications in the flight operations manual , the UASC&TCs flight Safety Review Board and the Manufacturer ' s Instructions.Ohio/Indiana UAS Center & Test Complex 1 4170 Allium Ct ., Springfield, OH 45505 937-497
-6739
Manufacturer Instructions for maintenance and use of safety checklists prior to flight. The UASC&TC will ensure that the sUAS is in an airworthy condition prior to each flight based
on compliance with the specifications in the tlight operations manual , the UASC&TCs Flight Safety R eview Board and the Manufacturer ' s Instructions.
14 CFR § 91.9 (b) (2) Civil aircraft flight manual, marking and placard requirements This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. The UASC&TCs UAS are small and will not carry any passengers. An equivalent level of safety will be accomplished by keeping the flight manual at the ground control station where the PIC will have immediate access to it during all flights.
14 CFR § 91.103: Preflight Action This regulation require s each PIC to take certain actions before flight to ensure safety of flight. As FAA approved flight manuals will not be provided for the sUAS, an exemption from this regulation is required. An equivalent level of safety will be provided by the PIC following the procedures set forth in the UASC&TCs Flight Operations Manual and Manufacturer's Instructions. The PIC will take all actions including reviewing weather, flight battery or fuel requirements, takeoff and landing distances and aircraft performance data before initiation ofthe flight. The PIC will also account for site specific conditions in their preflight actions.
14 CFR § 91.109 Flight Instruction This regulation provides that no person may operate a civil aircra'ft (except a manned free balloon) that is being used for flight instruction unless that aircra'ft has fully functioning dual controls. sUAS by their design, typically do not have functional dual controls. Given the size and speed ofthe sUAS, an equivalent level of safe training can be performed without dual controls because no pilot or passengers are aboard the aircraft and all persons will be a safe distance away in the event the sUAS experiences any difficulties during the flight instruction.

14 CFR 

### § 91.119 : Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Section 91.1 19( d) allows helicopters to be operated at less than the minimums prescribes, provided the person operating the helicopter complies with any routes or altitudes prescribed for helicopters by the FAA

. As this exemption is for sU AS that are similar to helicopters , and the exemption request authority to operate at altitudes up to 400ft AGL, an exemption may be needed to allow such operations. The sUAS will not be operated above 400 ft AGL. The equivalent level of safety will be achi eved given the size, we ight and speed ofthe sUA S as well as the location of operation. The lowaltitude operations ofthe sUAS will ensure separation between the sUAS and operations of conventional aircraft that must comply with 91.1 I9.

14 CFR § 9 1.121: A ltimeter Settings This regulation requires that each person operating an aircraft shall maintain the cruising altitude by reference to an altimeter that is set "to the elevation ofthe departure airport or an appropriate altimeter setting available before departure. " An exemption is required as the sUAS do not have a barometric altimeter, but instead have GPS altitude read out. An equivalent level ofsafety will be achieved by the PIC confirming the altitude ofthe launch site shown on GPS altitude indicator before flight.Ohio/Indiana UAS Center & Test Complex 1 4170 Allium Ct., Springfield, OH 45505 937-497
-6739
14 CFR § 91.151 (a): Fuel Requirements for Flig ht in VFR Cond itio ns The regulation prov ides that no person may begin a flight in an airplane under day- VFR conditions unless there is enough fuel to fl y to the first point of intended landing and to fly after that for at least 30 minutes

. An equivalent level of safety will be achieved due to operations being conducted on site without significant transit time by the sUAS. The maximum total flight time for each flight will be limited to the amount of the sUAS can be flown and still maintain a re serve battery power or fuel quantity of no less than 25%.
14 CFR 

### § 91.203 (a) and (b); Carrying Civil Aircraft Certification and Registration Subpart (a) ofthis regulation prohibits any perso n from operati ng a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; (2) an effective U.S. reg istrati on certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft Registration Application as provided for in §47.3l(c). Subpart (b) requires that no person may operate a civil aircraft unless an airworthiness certificate or a special flight authorization issued under § 91

. 715 legible to passengers or crew is displayed at the cabin or cockpit entrance. The sUAS platforms weigh no more than 55 pounds fully loaded and are operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to display them. An equivalent level of safety will be achieved by keeping these documents at the grou nd control station where the pilot flying the s UAS will have immediate access to them.Ohio/Indiana UAS Center & Test Complex 1 4170 Allium Ct

. , Springfield, OH 45505 937

-497

-6739 Append ix B


### OPERA TOR'S MANUALS
Attachments:
l. Sensefly eBee Users Manual 2. Event 38 Unmanned Systems, Inc. , E384 O perators Manual and Maintenance Manual 3. Altavian Nova F6500 Operators Manual 4. Peregrine UAS Manual 5. DJI Phntom 2 Users Manual and Ground Statio n Manual 6. MLB Bat-3 User Manual 7. Sensefly Swinglet User Manual