MASSACHUSETTS INSTITUTE OF TECHNOLOGY

LINCOLN LABORATORY

244 WOOD STREET

LEXINGTON, MASSACHUSETTS 02420

- 91 08

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 Refo rm 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 Syst em (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 neede d:

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 9 1.203(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 Defens e 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 02420Point 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

- 1200GLOSSARY OF ABBREVIATIONS

AGL A bove 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 Condit ions

VO Visual ObserverINTRODUCTION 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 th e 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 program s 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 foll owing 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 takeo ff 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 wi ng 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 mater ial 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 ai rspace system or the public." Given the

small size o f the UAS involved and the pre

- planned environment within which they will operate, the applicant believes that these operations fall squarely within that zone ofsafety (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 t he 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 an d 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,

Pu erto 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 ov ersees 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 o f 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 appropr iate 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 operationa l 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 ho urs 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 loc ated 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 aircrafttraffic in the vicinity. Should an aircraft enter the pattern the UAS will land ASAP

and remai n on the gr ound 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 m ust 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 autopil ot system. The UAS will utilize GPS navigation, failsafe s, 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 op erating 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 pop ulated 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 ra dio 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 bou ndary 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 la nd 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 Ad ministrator 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 governmen t 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,

alteratio ns 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 applicatio n. 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

Gran t of Exemption to A straeus 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

– Airworthin ess 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 s eeks 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 airc raft 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 Romancapital letter “N” and the registration number is displayed o n limited, restricted or light

sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to th e 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 letteri ng 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 marki ngs 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 ex emptions 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 th e 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

a ccess 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 Limitat ions

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 ca rry 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 curr ent 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 s tipulates (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 airworthines s 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 stati on 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 cas e 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 l ocal 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 equivalen t 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 altitudereadout. If no barometric sensor is aboard the UAS, a GPS derived altitude similarly set

to ze ro 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 cruisin g 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 condition s) 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 f

light 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

r estriction would be mo re 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 inspectio n 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

rec ords 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 requiremen t 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 Ex emptions 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 c ommand 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 exemp tion 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 takeo ff 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 w ith 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. 1106 6, 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) O ver 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 conges ted 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 requ ired 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 P UBLIC INTEREST

As introduced above, the requested exemption would authorize the Applicant to perf orm 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, t raining 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 p er 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 substa ntially 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 Transportatio n’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

efficie nt and less costly research and development missions, and produce much higher data quality.

SUMMARY OF REGULATIONS FROM WHICH PETITIONER SEEKS

EXEMPTION OR RELIEF14 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