June 26, 2015 

Docket Operations 

Ohio/Indiana UAS Center & Test Complex 1 4170 Allium 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 

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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 UASC&TC, a government entity operating within the Ohio Department of 

Transportation, coordinates, facilitates and supports state agencies and universities 

with their sUAS programs and operations. This exemption will allow the 

UASC&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 in 
Ohio/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 UAS 

operations 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 Complex 

ATTN: Richard Honneywell, Executive Director 

Phone: 93 7 716-0944 

Emai I: Richard .honneywell@dot.ohio.gov 

Address: 4170 Allium Court, Springfield, Ohio 45505 

The UASC&TC proposes to use the following sUAS platfo rms for operations under 

this request: 

1. SenseFly eBee 

2. Event 38 Unmanned Systems Inc., E3 84 UAS 

3. Altavian Nova F6500 

4. Peregrine UAS 

5. DJIPhantom 

6. MLB Bat-3 

7. SenseFly Swinglet 

The manufact urer instructions will be used in conjunction with the UASC&TC's Flight 

Operations Manual to ensure that the sUAS platforms are operated safely. 

Each of these platforms we igh less than 55 lbs, including energy sources and 

equipment. Manufacturer-provided manuals and checklists are enclosed with this 

request. Each UAS consists of a lightweight battery powered aircraft, a PC-based 

ground control station, and associated communications equipment. The aircraft 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 guidance. 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 

NOT AM is properly filed, the weather exceeds all minimum conditions, all pre-flight 

checks are complete and that UAS performance is satisfactory fo r flight in the NAS. 

Below is a summary of operational limitations and conditions that will ensure we 

operate at an equivalent or higher level of safe ty for each regulation requiring an 

exemption: 

1. The UASC&TC will obtain an Air Traffic Organization (ATO) issued Certificate of 
Ohio/Indiana UAS Center & Test Complex 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 sight (VLOS) of the PIC at 

all times. 

9. The s U AS will not be operated less than 500 feet below or less than 2,000 

feet horizontally from a cloud or when visibility is less than 3 statute miles 

from the PIC. 

10. All operations will utilize 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 distance 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 

available 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 is 
Ohio/Indiana UAS Center & Test Complex 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 

flight 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 Manuals 
Ohio/Indiana UAS Center & Test Complex 14170 Allium Ct., 

Springfield, OH 45505 

937-497-6739 

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Appendix A 

EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY 

The Ohio/Indiana Unmanned Aircraft Systems Center and Test Complex requests an exemption from 

the following regulations: 

14 CFR Part 21, Subpart H: Airworthiness Certificates 14 CFR § 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 populated 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 platforms carry no personnel or explosive materials and will operate exclusively within 

the operations area defined in an approved COA. Operations under this exemption will be tightly 

controlled and monitored by the PIC. The FAA will have advance notice of all of these sUAS 

operations. These safety enhancements provide a greater degree of safety to the public and property 

owners than conventional operations conducted with airworthiness certificates under 14 CFR Part 

21, Subpart H. 

14 CFR § 61.113 (a) & (b): Private Pilot Privileges and Limitations: Pilot in Command 

Part 61.113 (a) & (b) limits private pilot privileges to non-commercial operations. Unlike a 

conventional aircraft that carries a pilot, passengers or cargo, the sUAS is remotely controlled and 

carries no passengers or property. All sUAS flights will be planned and coordinated in advance and 

the operations area will be controlled. The level of safety provided by the requirements in the 

UASC&TC's Flight Operations Manual and the Manufacturer Instructions exceeds that provided by 

an individual holding a commercial pilot's certificate operating a conventional aircraft. Because the 

sUAS carries no pilot or passengers, the proposed operations can achieve the equivalent level of 

safety of current operations by requiring the PlC to have a private pilot's certificate rather than a 

commercial pilot's cettificate to operate the sUAS. 

14 CFR § 91.7 (a): Civil Aircraft Airworthiness 

This regulation requ ires that no person may operate a civil aircraft unless it is in an airworthy 

condition. As there will be no airworthiness certificate issued for the sUAS, should this exemption 

be granted, as no FAA regulatory standard exists for determining sUAS airworthiness. 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 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 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 Review 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 requires 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 of the 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 of the 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 of civil 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 sUAS 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 achieved 

given the size, weight and speed of the sUAS 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 I 9. 

14 CFR § 91.121: Altimeter 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 of the 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 of safety will be 

achieved by the PIC confirming the altitude of the 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 Flight in VFR Conditions 

The regulation provides that no person may begin a flight in an airplane under day-VFR 

conditions unless there is enough fuel to fly 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 reserve 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) of this regulation prohibits any person from operating a civil aircraft unless it has 

within it (1) an appropriate and current airworthiness certificate; (2) an effective U.S. registration 

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 ground control station where the pilot flying the sUAS will have 

immediate access to them. 
Ohio/Indiana UAS Center & Test Complex 1 4170 Allium Ct., 

Springfield, OH 45505 

937-497-6739 

Appendix B 

OPERA TOR'S MANUALS 

Attachments: 

l. Sensefly eBee Users Manual 

2. Event 38 Unmanned Systems, Inc., E384 Operators Manual and Maintenance Manual 

3. Altavian Nova F6500 Operators Manual 

4. Peregrine UAS Manual 

5. DJI Phntom 2 Users Manual and Ground Station Manual 

6. MLB Bat-3 User Manual 

7. Sensefly Swinglet User Manual