7925 Jones Branch Drive, Suite 6200 9800 Fredericksburg Road

McLean, Virginia 22102 San Antonio, Texas 78288

Ms. Thuy Cooper Senior Rulemaking Analyst Airspace and Airmen Rules Division-ARM 106 Office of Rulemaking

Federal Aviation Administration 800 Independence Avenue SW December 19, 2014 Washington, DC 20591

Reference: Requested Additional Information to USAA Petition for Section 333 Exemption- Docket No. FAA-2014-0796

Dear Ms. Cooper,

Thank you for your correspondence, dated December 5 , 2014, in which you requested additional information regarding USAA’s petition fo r exemption submitted October 3, 2014 pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012.

USAA has identified the unmanned aircraft system as a technology which can alleviate safety concerns associated with manned inspections in the air and on the ground, and provide enhanced service and experience to our membership i n a safe and efficient environment.

Your correspondence requests us to further explain or describe the process used to determine if the UAS is airworthy and in safe condition for oper ation in the NAS and to describe the process used to document UAS discrepancies and the correcti ve action taken in the aircraft record. Below are our answers to this requested information

.

Regarding the process used to determine if the UAS is airworthy and in safe condition for operation in the NAS

USAA proposes to operate the PrecisionHawk Lancaste r HawkEye within this exemption. This UAS platform has gained substantial operational mat urity via several FAA approved Certificates of Authorization allowing use within the National A ir Space (NAS). It has a proven safety record and has demonstrated that its operations would not adversely affect safety compared to similar

aircraft that have been issued an airworthiness cer tificate under 14 CFR Part 21, Subpart H.

Given the size, weight, speed and limited operating area associated with the UAS to be utilized, an exemption from 14 CFR Part 21, Subpart H, subjec t to certain conditions and limitations imposed by the FAA, meets the requirements for an e quivalent level of safety under 14 CFR and Section 333. PrecisionHawk Flight Manual, Maint enance Schedule and other training documents will be submitted confidentially for revi ew.

The PrecisionHawk Lancaster HawkEye unmanned aircra ft system (UAS) to be operated under this exemption is a fixed-wing aircraft, weighing l ess than 5.5 pounds fully loaded, flies at a slow speed (at or below 28 mph) and carries neither a pi lot nor passenger, carries no flammable fuels, and operates exclusively within a pre-disclo sed area in a controlled environment. Operations under this exemption will be tightly con trolled and monitored by the operator.Federal Aviation Administration

December 19, 2014 Page 2 of 4

The provided (confidential) PrecisionHawk Lancaster HawkEye Flight Manual, Maintenance Schedule and training documents, serve to ensure th e UAS is in a safe condition for operation. Furthermore, all Pilots in Command (PIC) have atten ded a manufacturer’s training program and

are most familiar with the UAS and are best suited to maintain the aircraft in an airworthy condition. Additionally, the PrecisionHawk Lancaste r HawkEye Flight Manual and Maintenance Schedule contain procedures for periodic inspection s and replacement intervals for the airframe and components.

In accordance with 14 CFR Part 91.7(b), the PIC of the UAS will be responsible for determining

whether the aircraft is in a condition for safe fli ght and that the planned operation can be completed safely with the conditions set forth in t he manufacturer’s flight manual. USAA will also follow the guidance of the other approved exemption s that state the UAS should remain clear and yield the right of way to all other manned oper ations at all times, operate only in visual meteorological conditions (VMC) and maintain the ap propriate visibility and cloud clearance per the operational airspace requirements.

USAA has also proposed other safety limitations and conditions that will provide an enhanced level of safety and will be the guiding principles when USAA is conducting operations under this exemption:

• The PrecisionHawk Lancaster Hawkeye maximum take-o ff weight will be 5.5

pounds. Detailed specifications are included in the confidential attachments. The fixed winged UAS platform that USAA is seeking to u tilize through this exemption is currently operating safely within the national a irspace pursuant to several COAs granted by the FAA to Texas A&M College Statio n and other public

entities. One these COAs was for the use of the Pre cisionHawk Lancaster HawkEye – the type of UAS that USAA seeks to utiliz e -to provide aerial imagery and mapping for authorities at the recent Washingto n state mudslides in Oso, WA. Other COAs have been approved for this particul ar platform through other public entities, which demonstrates the confidence that the FAA has for this manufacturer’s operational and safety protocol. USA A has attached the PrecisionHawk Lancaster’s Flight Manual, Maintenanc e Schedule, and training documents for review within this exemption applicat ion. USAA would operate in

accordance with all of these documents.

• All PIC and visual observers (VO) will complete FA A certified private pilot ground school and will have taken and passed the FAA Priva te Pilot Written Exam. This ensures that all PIC and VO have the knowledge rega rding the Federal Aviation Regulations, Airspace, and other pertinent knowledg e to conduct safe operations of small unmanned aircraft systems. A USAA employee with a FAA commercial pilot certificate and flight instructor certificate (USAA Safety Officer) that has been trained on UAS operations will oversee all tra ining/operations and ensure all PIC and VO receive proper training and abide by all pertinent regulations. This employee/FAA commercial pilot will meet all the fli ght review requirements specified in 14 CFR Part 61.56 in an aircraft in wh ich the PIC is rated on her/his flight certificate. All PIC and VO will be trained in detail to each of the unmanned aircraft system platform’s operations, systems and emergency procedures andFederal Aviation Administration

December 19, 2014 Page 3 of 4

passed every level of training on the platform and pass the manufacturer’s test

administered by the USAA employee/CFI (Trained by t he UAS manufacturer on the platform). Training records will be kept at USA A for every PIC and VO and will be available for review. Every PIC and VO will obtain an FAA Class 2 medical

certificate.

• All flight operations will be operated at an altit ude of no more than 400 ft above the ground (AGL) within daylight VFR conditions and within visual line of sight (VLOS) of the PIC and VO. The UAS will remain clear and yield the right of way to all other manned operations and activities at al l times. All operations will utilize

at least one VO and the PIC and VO will be able to communicate verbally at all times. All flight operations are to be conducted wi thin Class G (uncontrolled airspace) and some Class E (with prior authorizatio n). No flight operations will be operated within Class A, B, C or D airspace or spec ial use airspace. Areas of operation will be on USAA’s secured campus in San A ntonio, Texas and other designated remote, unpopulated areas around the San Antonio, Texas area within Class G airspace. These areas are located a sufficient distance from any airport, heliport, military base or other location with aviation activity. All flights will be communicated to FAA Flight Service with posted N OTAMS prior to the flight(s).

• The maximum total flight time for each flight will be 90 minutes or less in duration. All flight operations will be terminated when the a ircraft has less than 20% battery life remaining.

• Flight operations and safety briefings will be con ducted prior to all planned small unmanned aircraft system flights and will be mandat ory for PIC and VO. Briefings will include weather reviews, take off, landing and aircraft performance data for those real time conditions, and full pre- and post- flight inspections/checklists and briefings for each specific unmanned aircraft syste m, including the ground control station being operated and account for any discrepa ncies (i.e. inoperable components, items or equipment that are not covered in the relevant preflight inspection sections of the operations manual.) Befo re conducting any flight, the radio frequency spectrum used for the operation and control of the UAS will comply with the FCC or other appropriate government oversight agency requirements.

• In the event of a communication lost link, the UAS will return to a specific predetermined location and once the UAS is safely r ecovered, all flight operations will cease until any communication/data link issues are properly resolved. The UAS will abort the flight in the event of unpredict ed obstacles or emergencies in accordance with the operator’s manual.

• Any incident, accident or flight operation that tr ansgresses the later or vertical boundaries of the operational area as defined by th e applicable COA will be reported to the FAA’s UAS Integration Office (AFS-8 0) within 24 hrs. Accidents will be reported to the National Transportation Safety B oard (NTSB) per instructionsFederal Aviation Administration

December 19, 2014 Page 4 of 4

contained on the NTSB Website: www.ntsb.com . USAA will suspend all flight

operations until the incident, accident, or transgr ession is reviewed by AFS-80 and authorization to resume operations is provided.

Describe the process used to document UAS discrepan cies and the corrective action

taken in the aircraft record

In accordance with 14 CFR Part 91.405, 91.407, 91.4 09, and 91.417, USAA seeks relief from these regulations and requests an exemption. USAA w ill follow all UAS manufacturer requirements regarding maintenance via the (confide ntial) manufacturer maintenance schedule. USAA will document all maintenance, overhaul, repla cement and inspection requirements, as well as any preflight inspection procedures that ac count for discrepancies not already covered in the manufacturer’s manual; documentation of mainten ance records and will partner with the UAS manufacturer to develop UAS technician qualific ation criteria.

A USAA-approved UAS technician or the UAS manufactu rer will approve the UAS to return to service/operation after it has undergone maintenanc e, rebuilding or alternation. The UAS PIC may approve the UAS for return to service after per forming any preventive maintenance. USAA will keep UAS maintenance records that contain the following information: name of the person performing the maintenance, description of work per formed, and date of work completion/returned to service. All maintenance, pr eventive maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS will be recorded

and documented in the UAS aircraft records. USAA wi ll comply with all manufacturer safety

bulletins.

Allowing USAA this exemption would give USAA the ab ility to continue our UAS research and development beyond the limits imposed today. Additi onal testing would benefit not only USAA and its membership, but would serve as a partnershi p with the FAA and others within the UAS community to advance this new and emerging technolo gy in a safe and controlled environment.

Sincerely,

Greg Cirillo Wiley Rein LLP

Counsel for USAA 

# Michael Burns

Michael Burns

Assistant Vice President

USAA