MASSACHUSETTS INSTITUTE OF TECHNOLOGY

LINCOLN LABORATORY

244 WOOD STREET

LEXINGTON, MASSACHUSETTS 02420-9108

Area Code 781

15 December 2015 981-1200

U.S. Department of Transportation 

Docket Operations

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Petition for Exemption and Relief from Specific Regulations of Title 14 of the Code 

of Federal Regulations Pursuant to Section 333 of the FAA Modernization and Reform 

Act of 1012 (Public Law 112-95) Regarding Commercial Employment of Unmanned 

Aircraft Systems (UAS)

Dear Sir/Madam,

Pursuant to Section 333 of Public Law 112-95 commonly known as the “FAA 

Modernization and Reform Act of 2012” or “The Reform Act”, MIT Lincoln Laboratory 

hereby applies for authorization to conduct commercial unmanned aerial systems (UAS) 

operations within the United States National Airspace System (NAS) for the purpose of 

Research, Education and UAS platform development.

Federal Register Summary

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

Federal Register, should it be determined that publication is needed:

MIT Lincoln Laboratory 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 research, education and UAS platform development for the 

Department of Defense and other Government agencies. 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.

The name and address of the applicant is:

MIT Lincoln Laboratory

244 Wood Street

Lexington, MA 02420
Point of contact for specific contact information is:

John G. Benkert

MIT Lincoln Laboratory 

Flight Test Facility Manager

244 Wood Street

Lexington, MA 02420

Benkert@ll.mit.edu

781-981-1200
GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airmen

PIC Pilot in Command

Section 333 FAA Modernization and Reform Act of 2012, Section 333 

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aerial System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer
INTRODUCTION AND INTEREST OF THE PETITIONER

The use of unmanned aerial systems (UAS) by the Department of Defense (DOD) and 

other Governmental agencies has greatly increased over the last several years. These 

devices are used regularly to reduce costs and increase safety compared to the use of a 

manned aircraft to perform the same mission. In order to meet the need for the 

development of new systems to be operated by these UASs, MIT Lincoln Laboratory is 

developing a UAS program to safely run the development and flight test programs of 

these new systems. To accomplish this, our research programs must engage in domestic 

UAS operations for research, education and training purposes. Due to the nature of our 

work, these flights will occur predominantly over remote areas, away from human 

activities. 

UNMANNED SYSTEM CHARACTERISTICS

The applicant proposes the use of the following airframes:

- DJI Phantom 2

- DJI Phantom 3

- AeroVironment RQ-11 Raven

- AeroVironment RQ-20 Puma

The DJI Phantoms2 and 3 are rotorcraft, while the RQ-11 Raven and RQ-20 Puma are 

fixed wing aircraft. All of these aircraft have a maximum gross takeoff weight of less 

than 55 pounds and have a maximum airspeed of less than 87 knots.

QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM 

ACT

The proposed operations in this petition for exemption qualify for expedited approval 

under Section 333 of the Reform Act. Each of the statutory criteria and other potentially 

relevant factors are satisfied.

The proposed operations would permit the use of small and relatively inexpensive UAS 

under controlled conditions in airspace that: (1) is limited; (2) is predetermined; (3)is 

away from populated areas; (4) would provide an increased level of safety beyond that 

existing when fixed or rotor wing aircraft are used to accomplish the same purpose.

The UAS's planned to be operated are rotorcraft and fixed wing aircraft, each weighing 

typically less than 15 lbs., and always less than 55 lbs., including payload. They would 

operate, under normal conditions, at a speed of typically no more than 60 knots, but 

always under 87 knots. The principal construction material of the UAS aircraft would 

typically be foam, carbon fiber, aluminium and/or plastic. Operations will be performed 

by a qualified UAS Pilot in Command (PIC), as outlined below, to insure that the UAS 

will "not create a hazard to users of the national airspace system or the public." Given the 

small size of the UAS involved and the pre-planned environment within which they will 

operate, the applicant believes that these operations fall squarely within that zone of 
safety (an equivalent level of safety) in which Congress envisioned that the FAA must, 

by exemption, allow commercial operations of UAS to commence immediately. Also, 

due to the size of the UAS and the pre-defined, restricted area in which the UAS will 

operate, approval of the application presents no national security issue. The operation of 

UAS by knowledgeable professionals will serve to enhance safety, add to the public 

benefit, and reduce environmental impacts related to current methods of manned aircraft 

flight operations. These limitations and conditions to which the operator, or its 

employees, acting as UAS PIC agrees to be bound when conducting commercial 

operations under a FAA issued exemption:

1. Operations authorized by this grant of exemption are limited to the following aircraft: 

DJI Phantom 2, DJI Phantom 3, AeroVironment RQ-11 Raven, and AeroVironment 

RQ-20 Puma.

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 87 knots.

5. The UAS PIC will 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 Columbia, 

Puerto Rico, a territory, a possession, or the Federal government. The PIC must also 

meet the recent flight experience requirement stated in 14 CFR § 61.57 and flight 

review requirements stated in 14 CFR § 61.56. The MIT Lincoln Laboratory Flight 

Facility oversees the UAS program, and ensures these requirements are met.

6. In addition to holding an FAA issued airman certificate, UAS PIC must complete a 

MIT Lincoln Laboratory Flight Facility UAS Training Program. This training will 

include a detailed review of FAA regulations/requirements and MIT Lincoln 

Laboratory Flight Facility procedures to safely operate the UAS in a manner consistent 

with how the UAS will be operated under this exemption (to include evasive and 

emergency maneuvers and maintaining appropriate distances from persons, vehicles, 

vessels and structures). 

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

operational control tower, or 2 NM of an airport without a published instrument flight 

procedure or operational control tower, or 2 NM of a heliport with a published 

instrument flight procedure. Flights will be operated in Class G airspace whenever 

possible. If operation in other airspace is required, the relevant controlling agency 

will be notified at least 24 hours prior to the operation and, if required, any necessary 

permission obtained.

A Letter of Agreement (LOA) has been signed with the Gardner Municipal Airport 

(KGDM) to use a site that is located on the airport property, a copy of the LOA is 

included as a separate attachment to this petition for exemption. KGDM has 

published instrument flight procedures, but does not have an operational control 

tower. KGDM was chosen since it has very little aircraft movement and is located in 

a remote area. The UAS operators will have a VHF radio tuned to the KGDM 

Common Traffic Advisory Frequency (CTAF) for situational awareness of aircraft 
traffic in the vicinity. Should an aircraft enter the pattern the UAS will land ASAP 

and remain on the ground until all manned aircraft activity is complete. A NOTAM 

will be issued when UAS operations will be performed.

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.

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. The UAS will be equipped with an autopilot system. The UAS will utilize GPS 

navigation, failsafes, return-to-home (RTH) and flight abort safety features applicable 

to each specific UAS.

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 copy of current Letters of Agreement will be 

delivered as a separate attachment. 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, the UA will return to a predetermined location 

within the established flight boundary and land. For loss of GPS signal, the UAS will

be recovered in accordance with the 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 Manual will be maintained for each UAS. When the PIC signs 

for the aircraft they are signifying that all required maintenance activities, repairs, 

alterations and inspections have been accomplished.

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 check flight (FCF). No additional flights will be accomplished until a 

successful FCF has been completed.

SPECIFIC SECTIONS OF 14 CFR FROM WHICH PETITIONER SEEKS 

EXEMPTION OR RELEIF

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 lightsport 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, two-inch 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 400 

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 UAS 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 

ensured by the requirement that each UAS PIC will perform a complete inspection of the 

aircraft prior to each flight. 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 400 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

As introduced above, the requested exemption would authorize the Applicant to perform 

commercial operations with UAS that will provide significant benefits to the public 

interest:

1. The commercial use of UAS to perform research and developmental activities at MIT 

Lincoln Laboratory in support of government entities, private research institutions, and 

scientific studies is warranted as these activities are critical to the well-being of the 

general public. 

2. A significant reduction in costs to conduct research, training and education programs 

versus the use of manned aircraft. At present, the cost to our research programs that 

use manned aircraft for flight test can be in the tens of thousands of dollars per day. By 

incorporating UAS into these programs we can incur significant savings and more 

efficiently conduct research in the public interest.

3. The use of UAS will decrease congestion in the National Airspace System along with 

reducing the noise and air pollution generated during traditional manned aircraft flight 

operations.

4. When using UAS to complement field personnel, they reduce safety concerns when 

gathering data from inaccessible or unstable/unsafe areas and in extreme weather or 

terrain.

5. Operation of UAS will substantially reduce the risk to life and property in the air, and 

on the ground, which is commonly associated with traditional manned aircraft flight 

operations.

Approval of this exemption would thereby enhance safety and fulfill the Secretary of 

Transportation’s (the FAA Administrator'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." Approval of this exemption will allow for safer, more 

efficient and less costly research and development missions, and produce much higher 

data quality.

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)

SUPPORTING DOCUMENTS

To be delivered under separate attachment:

Letter of Agreement between MIT/LL and Gardner Municipal Airport

Letter of Agreement between MIT/LL and Andre Guertin