1

Paul	Kaup STEM+C	Inc. 8720	Country	Shire	Lane Spring	Grove,	IL	60081 Prkaup@gmail.com Cell	(708)	359

- 5289 Seek Exemption 14 CFR	Section 333 P.L. 112-95; Special Rules	for	Certain Unmanned Aircraft System

. Stem+C	in	cooperation	with	Spaceport	America are seeking	a	2 day	exemption.		The exemption	period	would	apply	for	(Saturday)	April	30, 2016	at	13 :00utc (06:00am Mountain	Time)	through Sunday May	1 ,	2016 at	0200utc	(07:00pm	Mountain	Time) .	Any adjustment	to	the	listed	dates	would	be	requested	in	writing	by	Paul	Kaup	(no	less	than	5 days	prior	to	the	authorization	period)	to	be	authorized	by	the	administrator. The	2 day	exemption	would	be	for	an event	titled	“Spaceport	America	and	STEM+C	Flight Series ”. 2	to 4	teams	of	students	from	the	United	States	will	participate	in	this	2	day	STEM (Science,	Technology,	Engineering	and	Math)	event

. 2	teams	representative	of	STE M+C	will participate	in	this	event.		STEM+C	will	invite	2	other	teams	to	participate	in	this	event.		All teams	who	are	authorized	to	participate	in	this	event	will	follow	the	guidelines	contained within	this	request. Please	reference	the	link	below	for the	event	web

- page. The	event	will	take	place	at	Spaceport	America. Spaceport Co	Rd	Ao21 New	Mexico	87901 Airspace	use	will	be	coordinated	by	Spaceport	America	in	conjunction	with	agreement	with the	White	Sands	Missile	Range,		ZAB	(Albuquerque	Center),	and the	local	ATC	facilities. Preliminary	approval	and	coordination	has	already	been	granted this	exemption	request. Local	notams	will	be	issued	by	Spaceport	America	and/or	STEM+C	Inc.	with	the	local	FAA ATC	facility. Airspace	use	will	be	defined	as	35 nm	radius	from	a	point	defined	by	Lat	32.9905	Long

- 106.9736	up	to	115,000ft	msl. Actual	day	of	use	requirements	will	be	much	less	than anticipated,	and	will	be	no	more	than	a	very	small	slice	of	the	requested	airspace. About	STEM+C	Inc: STEM	...	defined as	“Science,	technology,	engineering	and	math”. STEM+C	is	an	educational	company. The	goal	of	STEM+C	is	to	bring	STEM+C	(Science, Technology,	Engineering,	Math	+	Creativity)	into	classrooms	across	the	Country	and	help raise	a	generation	of	Science	and	M ath	literate	students.		Big	projects	inspired	our	Nation	to do	great	things	in	the	1960’s	during	the	Space	Race. STEM+C	takes challenging	projects	into2

the	classroom	to	anchor	all	areas	of	study	to	a	common	goal. The	event is	designed	to	inspire creativity,	develop	problem	solving	skills,	critical	thinking	and	bring	awareness	to	the	inter

relatedness	of	all	things. STEM+C	uses hands

- on	projects	to	anchor	STEM	concepts	to	the	teaching	curriculum	in	the school. Anchoring	all	areas	of	study	to	a	common	goal gives	cross
- relevance	between	subject matter. This	has	proven	to	be	very	effective	at	enhancing	critical	thinking	and	problem solving	skills. Here	are	the	2012	PSIA	results.		The	U.S.	currently	ranks	35 th in	math	and	27th in	science. **These	statistics need	to	change**  !	And	we	at	STEM+C	Inc	are	doing	our	best	to	make	that happen.3

I	realize	the	responsibility	of	what	I	am	asking	of	the Administrator.			The	dawn	of	UAV’s	is upon	us,	and	this	event	provides	a	window	of	opportunity	to	provide	an	enhanced	learning experience with	an	emphasis	on	safety.		This	event	is	our	kids	generation	equivalent	of “October	Sky”.		I	look	forward	to	working	with	the	administrator	to	help	make	this	event happen	for	our	next	generation	of	Scientist,	and	Engineers. Please	advise	me	of	any	other necessary	documentation	or	information	that	you	may	need	in	authorizing	this	request. Thank	you, Paul	Kaup CEO	STEM+C	Inc.4 UNITED	STATES	OF	AMERICA DEPARTMENT	OF	TRANSPORTATION FEDERAL	AVIATION ADMINISTRATION DOCKET MANAGEMENT	SYSTEM	1200 NEW	JERSEY	AVE.,	SE	WASHINGTON,	DC

20590 **IN	THE	MATTER	OF	THE	PETITION	FOR	EXEMPTION OF:**  

## STEM+C **and	authorized/registered	teams**

**FOR AN**  **EXEMPTION	SEEKING	RELIEF	FROM	THE REQUIREMENTS	OF	THE	FAA	REFORM	ACT**  **AND PART	11	OF	THE	FEDERAL**  **AVIATION	REGULATIONS FROM**  **TITLE	14	OF	THE	CODE	OF	FEDERAL REGULATIONS**  **SECTIONS	C.F.R.	§§	61.113	(a)	&	(b);	91.7(a);	91.119	(c);	91.121; 91.151(a);**  **91.405	(a);	91.407(a)	(1);	91.409	(a)	(2);	91.417	(a)	& (b).**  **CONCERNING	NON -**  **COMMERCIAL	OPERATION	OF	UNMANN ED	AIRCRAFT**  **SYSTEMSD	PURSUANT TO	SECTION	333	OFD	THE	FAA**  **MODERNIZATION AND	REFORM	ACT	OF	2012	(PUBLIC	LAW**  **112 -**  **95)**

Submitted	on February	1 ,	2016 STEM+C	Inc. Paul	Kaup 8720	Country	Shire	Lane Spring	Grove,	IL	60081 prkaup@gmail.com cell	(708)	359

- 52895



## T**able	of Contents**  **Glossary	of	Abbreviations	and	Terms p6**  **Introduction	and	Interest	of Petitioner**  **p7 Background	and	Expertise**  **p8 Description	of	Requested	Place	and	Time**  **p9 Description	of	sUAS/UAS**  **p10 Non** **- Commercial	Purpose**  **p12 Regulations	from	which	Exemption	Relief**  **is	requested p12**  **Commitment	to	Safety p13**  **The	Exemption Request**  **p14 Operator	Requirements**  **p15 Equivalent	Level	of	Safety**  **p15 Federal	Register	Publication**  **p17 Summary**  **p18**6



## GLOSSARY	OF **ABBREVIATIONS AND	TERMS**  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 GPS Global	Positioning System LOL Loss	ofLink NAS National	Airspace System NOTAM Notice To Airman PIC Pilot In Command Section 333 FAA	Modernization	and	Reform	Act	of	2012	(FMRA) Section 333 RC Remote Control SO Safety Observer SOP Standard	Operating Procedures sUAS Small Unmanned Aircraft System sUAV Small Unmanned Aircraft Vehicle UA Unmanned Aircraft UAS Unmanned	Aircraft System UAV Unmanned Aircraft Vehicle VFR Visual	Flight Rules VLOS Visual Line of Site VMC Visual	Meteorological Conditions VTOL Vertical	Take

- Off	and Landing

**“**Spaceport	America	and	STEM+C	Flight	Series” **...** Also	referred	to	as	“event”. Dates	for	this event	will	be (Saturday)	April	30,	2016	at	13:00utc	(06:00am	Mountain	Time)	through Sunday	May	1,	2016		at	0200utc	(07:00pm	Mountain	Time). The	event	will	cover	a geographical	area	as defined	as	35	nm	radius	from	a	point	defined	by	Lat	32.9905	Long

- 106.9736,	from	ground	level	up	to	115,000ft	msl.		Actual	day	of	use	requirements	will	be	much less	than	anticipated. **“Team/teams”** ...	for	the	purpose	of	“Spaceport	America	and	STEM+C	Flight	Series”,	shall	also cover	all	registered	participants.		All	participating	teams’	information	will	be	collected	and maintained	by	STEM+C	Inc	and	made	available	to	the	administrator	upon	request.7



## INTRODUCTION	AND	INTERESTS	OF	THE **PETITIONER**
Dear	Sir	or Madam:
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, STEM+C Inc. Operator of Small Unmanned Aircraft Systems (“sUASs”) for the purpose of “Spaceport America and STEM+C Flight Series” is seeking a 10 day exemption from the listed Federal Aviation Regulations (“FARs”) to allow non- commercial operation of its sUAV’s/s UAS, so long as such operations	are	conducted within and under the conditions outlined herein or as may be established by the FAA in an exemption granted under either Section 333 or Section 49 U.S.C. §44701(f). This exemption would apply to all
“teams” of students registered and authorized by STEM+C Inc. to participate in
“Spaceport America and STEM+C Flight Series” during the applied for time and geographical	area. As described more fully below, the requested exemption would permit the operation of a sUAS/sUAV under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) date restricted. App roval of this exemption would thereby allow	STEM+C	Inc.	in	conjunction	with	Spaceport	America	to	host/conduct	this	event. This event is being organized to broaden awareness of all things STEM related and designed	as	to	cultivate	a	new	generation	of	innovation,	to	establish	a	new	generation of science literacy, and competency. The event will enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “... establish requirements for the safe operation of such aircraft systems in the national airspace	system.”	Section	333(c)	of	the	Reform Act. 1 Teams	shall	apply	to	STEM+C	Inc	via	a	google	form	for	application	for	this	event.		A	team must	be	authorized	by	STEM+C	Inc.	to	participate	in	“Spaceport	America	and	STEM+C Flight Series “. A	database	of	each	team	will	be	maintained	by	STEM+C	Inc.	and	made	available	to the	administrator	upon	request.		The	data	base	for	each	team	shall	include	the	following, 1. Team	Leader	name,	email	address	and	contact	phone	number

. 2. Residential	address	of	the	team	leader. 3. Individual	team	member	names, email	addresses		and	or	contact	phone	numbers 4. Grade	level	of	each	team	member

.8



## Background **and Expertise** 
I (Paul	Kaup)	am	a	pilot	(Captain) for	Southwest	Airlines,	and	CEO	of STEM+C	Inc. I	am	a space,	and	technology enthusiast. I	have	over	20000	hours	of	flight	time as	a	pilot	of	many different	types	of	airplanes. Of	those	20000	hours	of	flight	time,	nearly	3000	hours	is	as	an instructor	or	as	a	check

-airman	for	part	121	comp anies.		I	am	a	licensed	ATP	in	BE

- 1900D,	D

328JET,	and	B

- 737.		I	have	commercial	SEL	privileges	in	single	engine	aircraft.	I	have instructed	students	in	a	wide	range	of	aircraft	from	single	engine	Cessna	152	through	the	BE

1900D. In	addition	to	all	the above	qualifications,	I	am	an	RC	Airplane	hobbyist.		I	have	a	dozen	or	so years	of	experience	with	various	RC	airplanes,	Quad	Copters,	and	their	related	systems.		I have	experience	with	flying	aircraft	via	FPV(First	Person	View) ,	with	built	in	return	to	ho me and	auto	piloting	capabilities.		I	have	instructed	kids	and	adults	for	several	years	in	the	safe use	of	these	vehicles. I	am	also	an	AMA	member	(Academy	of	Model	Aeronautics)	member	....	#1082444 In	addition	to	the	above	qualification	I	have	flown	over 20	Near	Space	Balloon	flights	under CFR	14,	part	101,	subpart	D. I	am	the	holder	of	a	FCC	technician	radio	license.	FRN	#	0022508261.	Call	sign	KC9YMN I	am	more	than qualified	to instruct, and teach all	the students/participants	in	the	subject areas	mentioned	with	an	emphasis	on	aviation	safety.			I	have	over	27	years	of	experience	in aviation,	and	several	years	of	experience	in	sUAS/sUAV as	an operator,	and	in	the	assembly of	sUAS/sUAV	systems	and	aircraft.		I	am	more	than	qualified to	integrate	years of	aviation experience	with	the	advent	of	sUAS/sUAV	operations	and	systems. I	am	more	than	qualified	to	safely	oversee the “Spaceport	America	and	STEM+C	Flight Series ” event. I	have	been	working	with	students from	northern	Illinois in	grades	5 th through	12 th,	for	the past	6	years	in	the Spring	Grove	Elementary	School,	Richmond	Grade	School,	Nippersink Middle	School,	and	the	Richmond	Burton	H.S. I	have	used	robotics	and	aerospace	projects	to help	enforce	the	concepts	in	STEM.		In	my	first	2	years of	working	with	the	students,	I became	aware	of	the	lack	of	STEM	(Science,	Technology,	Engineering,	Math,	+C)	within	our schools	curriculum. I included	"+C"	because	I	feel	creativity	is	as	important	as the	other	4 areas. The goal	of	the	STEM+C	is	to	bring	real	life	project	based	learning	experiences	to	our kids. To	get	them	excited	about	Science,	Technology,	Engineering	and	Math. STEM+C	is trying	to	make	a	difference	in	the	areas	know	as	STEM.		STEM+C	engages	students	with project	based	learning,	with an	emphasis	on	aerospace.9 

## Description	of **Requested Place	and	time**  **of**
**“ Spaceport	America	and	STEM+C	Flight	Series** **”** Airspace	use	will	be	coordinated	by	Spaceport	America	in	conjunction	with	agreement	with the	White	Sands	Missile	Range	and	the	local	ATC	facilities.		Local	notams	will	be	issued	by Spaceport	America	and/or	STEM+C	Inc.	with	the	local	FAA	ATC	facility.		Airspace	use	will	be defined	as	35	nm	radius	from	a	point	defined	by	Lat	32.9905	Long - 106.9736	up	to	115,000ft msl	(please	see	the	chart	depiction	below). Actual	day	of	use	requirements	will	be	much	less than	anticipated. Actual	day	of	use airspace	requirements	will	be	a small	slice	of	the proposed	requested	airspace. “Spaceport	America	and	STEM+C	Flight	Series ”” requested date for this	event	will	be (Saturday)	April	30,	2016	at	13 :00utc	(06:00am	Mountain	Time) through	Sunday	May	1,	2016		at	0200utc	(07:00pm Mountain	Time)

. Spaceport	America	was	selected	for	this	event	due	to	the	remoteness	of	the	facility	which adds	a	significant	level	of	safety	for	the	requested	event.		The	weather	conditions	in	and around	Spaceport	America	are	idea	for	this	event	during the	requested	time	period.10



## Description	of	sUAV/**s UAS**  **Requested:** The	petitioner	is	seeking	an	exemption	to	non

-commercially	operate	sUAV/s UAS	for
“Spaceport	America	and	STEM+C	Flight	Series” as follows: sUAV

– All sUAVs used in this event will be primarily constructed of foam, and or fiberglass (EPO foam, EPP foam, or like material). Airframes may be reinforced with carbon fiber, glues, adhesives and tape as necessary. Total airframe weight for each vehicle	shall	be	less than	9lbs	(4.08kg). Wing	span	no	greater	than	....	3	feet Fuselage	length	no	greater	than	...7	feet Aircraft Height no	greater	than

... 1	feet The	aUAV/sUAV	is	an RVJET	FPV	Flying	Wing

- KIT	(U.S.	Pat.	No.	D734,402	S). **All sUAV** **s used**  **in this**  **event will**  **have registration**  **number: FA3KLHCMX7,**  **the registration**  **number will**  **be clearly**  **marked on**  **all sUAV** **s as**  **prescribed by**  **the FAA	before	the	operation	of	any**  **sUAV s**  **approved	for	this	event.**

Typical sUAS	vehicle	construction	will	consist	of	the	following	systems. Video link system
... operated in accordance with U.S. FCC regulations. Typical video link systems are constructed using a video camera, video transmitter, transmitter antennas, electronic filters, in conjunction with a GPS tracking system, and 12v power supply. Video Link frequency will be on the 1.3ghz specktrum. Transmission wattage	will	be	less	than	1watt,	in	accordance	with	U.S.	FCC	regulations. Control Link System

... operated in accordance with U.S. FCC regulations. Typical long range aircraft control system are constructed using a receiver operated on 433mhz, receiver antenna, receiver control signals are distributed from the receiver to various aircraft systems. Transmission wattage will be less than 1watt, in accordance	with	U.S.	FCC	regulations. UAV Tracking

... operated in accordance with U.S. FCC regulations. Typical tracking systems are constructed using a GPS signal antenna, a GPS receiver chip, and a GPS position transmitter

. s UAV tracking will utilize the APRS (Automatic packet reporting system), 144. 39mhz. Transmission wattage will be less than 1watt, in accordance	with	U.S.	FCC	regulations.11

Flight controls

... typical aircraft control construction, using ailerons, rudder, elevator, or elevon using typical RC airplane servos, linkage and receivers for control input	signals. Aircraft electrical system
... Primarily DC powered systems under 24 volts. Aircraft electrical system supply electrical power to video systems, control, tracking, aircraft thrust	systems,	and	other	systems	as	necessary.

See	the	below	include	image	for	an	example	of	proposed	sUAS/s UAV.12



## Non**- Commercial**  **Purpose:**
This exemption request, once granted would allow the petitioner and authorized teams to operate small unmanned aerial vehicle (sUAV/s UAV) during the
“Spaceport America and STEM+C Flight Series” at the authorized time and location of	the	event. The	sole	purpose	of	this	event	is	to	give	our	students	a	chance	to	learn through real world application of STEM with an emphasis on safety of operation of sUAV/sUAS. 

### Regulations	from	which	the	Exemption	Relief	is **requested:** 14	C.F.R.	§	61.113	(a)	&	(b) 14	C.F.R.	§ 61.133(a) 14	C.F.R.	§ 91.7(a) 14	C.F.	R.§ 91.119 14	C.F.R.	§ 91.121 14	C.F.R.	§	91.151 (a) 14	C.F.R.	§	91.405 (a) 14	C.F.R.	§	407	(a) (1) 14	C.F.R.	§	409	(a) (2) 14	C.F.R.	§	417	(a)	& (b) The	name	and	address	of	the Petitioner: STEM+C	Inc. 8720	Country	Shire	Lane Spring	Grove,	IL	60081 prkaup@gmail.com Cell	(708)	359

- 5289 36013



## Commitment	to **Safety** As part of its commitment to safety and innovation of new safety procedures with regard	to	the	operation	of	sUAV/s UAVs’, STEM+C	Inc. is	asking	for	this	exemption	in part, to explore how to reduce the risk of injury to persons and damage to property with	the	future	use	of	sUAV/sUAV	systems. A safety briefing will be given by a designated team leader before each flight. The safety	briefing	should	contain	the	following. 1. A weather briefing based on the current and forecast weather for the intended	flight. a. Local	weather	conditions,	wind,	temperature,	and	cloud	cover

. b. Low	level	wind	forecast,	as	well	as	upper	level	wind	forecast

. c. Predicted	flight	path

. d. The team leader and team members will make a go/no go decision based	on	the	above	information. 2. A discussion of the intended landing location, and alternate landing locations should	an	alternate	landing	location	become necessary. 3. The team	leader will be	responsible	to	see	that	a “pre

-flight checklist” is	used to ensure that all systems are checked and in safe working condition prior to flight. a. The checklist shall address the safe operation of each system installed in	the	sUAS/sUAV,	to	ensure proper	operation	for	the	intended	flight.14



## The	Exemption **Request** Stem+C	in	cooperation	with	Spaceport	America	is	seeking	a	2 day	exemption. The exemption	would	be	limited	by	date,	time	and	geographical	location. The	exemption	period would	apply	from (Saturday)	April	30,	2016	at	13 :00utc	(06:00am	Mountain	Time)	through Sunday	May	1,	2016		at	0200utc	(07:00pm	Mountain	Time)

. Any	adjustment	to the	listed dates	would	be	requested	in	writing	by	Paul	Kaup	(no	less	than	5 days	prior	to	the authorization	period)	to	be	authorized	by	the	administrator. The	2 day	exemption	would	be	for	an event	titled “Spaceport	America	and	STEM+C	Flight Series ”.		2 to	4 teams	of	students	from the	United	States	will	be	invited	to	participate	in	this event.		Please	reference	the	link	below	for	the	event	web

-page. https://sites.google.com/site/rftstars7/spring

- 2016

- event The	event	will	take	place	at	Spaceport	America. Spaceport Co	Rd	Ao21 New	Mexico	87901 Airspace	use	will	be	coordinated	by	Spaceport	America	in	conjunction	with	agreement	with the	White	Sands	Missile	Range	and	the	local	ATC	facilities.		Local	notams	will	be	issued	by Spaceport	America	and/or	STEM+C	Inc.	with	the	local	FAA	ATC	facility.		Airspace	use	will	be defined	as	35	nm	radius	from	a	point	defined	by	Lat	32.9905	Long

- 106.9736	up	to	115,000ft msl.	Actual	day	of	use	requirements	will	be	much	less	than	anticipated. This exemption application is submitted to fulfill Congress’ express goal in passing Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs/sUAVs do not create a hazard to	users	of	the	NAS or the	public	or	pose	a	threat	to	national	security	in	light	of the following:

 The sUAV’s/sUAS’s size,	weight,	speed,	and	operational	capability;
 Operation	of	the sUAS/sUAS in	close	proximity	to	airports	and	populated	areas; and
 Operation	of	the	sUAS/sUAV within	visual	line	of	sight	of	the Operator. Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id.	§333(c)	(emphasis added). 5 The Federal	Aviation	Act	expressly	grants	the FAA the	authority	to issue	exemptions

.15

This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act: The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702

-44716 of this title if the Administrator finds the exemption is in the public interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1) This authority to grant exemptions reaches such issues as authorization of commercial operation of aircraft without	an	FAA	issued	pilot’s license. **STEM+C Inc.**  **is filing**  **this	application as**  **a	request that**  **the FAA**  **combine	the	grant of**  **the Section**  **333 exemption**  **with a**  **standard Certificate**  **of Operation**  **(COA) that**  **will allow**  **non -** **commercial operations**  **of its**  **STEM+C Inc.**  **and all**  **registered**

**/authorized teams**  **to operate**  **sUAV s’/UAVs’**  **during the**  **a pplied**  **for date,**  **time and**  **location without**  **the necessity**  **of filing**  **for a**  **COA for**  **each flight,**  **unless such**  **flight is**  **to be**  **conducted in**  **an area**  **and or**  **time not**  **approved**

**/authorized	by the	exemption.**  

## Operator **Requirements** Given the sUAVs’/UAVs’ prop osed by STEM+C Inc and all registered teams for
“Spaceport America and STEM+C Flight	Series” operators	should	not	be	required	to hold a private p ilot license. STEM+C Inc. believes that the operator, instead of understanding	how	to	operate	a	passenger	carrying	aircraft,	should	have	knowledge and experience that enables the safe operation of a small, remotely piloted sUAV/sUAV and should understand airspace restrictions and know how to ensure separation	from	other	aircraft	as	well	as	non

-participants	and	property

. 

## Equivalent	Level	of **Safety 14	C.F.R.	§	61.113(a)	&	(b);:	Private	Pilot	Privileges	and	Limitations;	Pilot	in**  **Command;** Section 61.113(a) & (b) limit private pilots to non- commercial operations. Unlike a conventional	aircraft	that	carries	a	pilot,	passengers,	and	cargo,	the STEM+C	Inc.	and all event teams’, sUAV/sUAV are remotely controlled with no passengers or property of others on board. Section 61.133(a) requires an individual with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire. None of the proposed sUASs’/sUAVs’ of this event shall be of commercial intent,	for	compensation	or	hire. STEM+C	Inc.	and	authorized	teams	seek exemption from	this	part	for	the	authorized	“Spaceport	America	and	STEM+C	Flight	Series”.16



### 14	C.F.R.	§	91.7(a):	Civil	aircraft **airworthiness.** This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing non- commercial operation of the sUASs’/sUAVs’ without an airworthiness certificate, no standard will exist for airworthiness of sUASs’/sUAVs’

. STEM+C Inc. and authorized teams seek exemption from this part for the authorized “Spaceport America and STEM+C Flight Series”. STEM+C Inc. and all authorized teams will abide by the following airworthiness	requirements. In addition to the “preflight checklist”, each team shall have their sUAV/s UAV scrutinized by Paul Kaup and or a representative of STEM +C for safety and competency of construction. Any vehicle found in the opinion of Paul Kaup or the representative of STEM+C not to be airworthy will not be allowed to fly during authorized “Spaceport	America	and	STEM+C	Flight	Series”. An Airworthy sUAV/sUAV f or the purpose of “Spaceport America and STEM+C Flight	Series ” shall	meet	the	following	requirements. 1. A test flight of duration of a minimum of 2 minutes of flight time shall be demonstrated prior to the beginning of the event date in order to demonstrate	airworthiness. 2. The test flight shall be in a representative aircraft constructed of the identical structure and components of the proposed s UAV used for this event. 3. The test flight shall be recorded by an observer on the ground. The recorded flight shall be sent via ele ctronic means and or a recorded link (youtube or equvilant) sent to prkaup@gmail.com for further review and approval. O nce approved only minor modifications so as to not alter the UAV’s	flight	characteristics	shall be	made. 4. If the proposed sUAV is to be a glider (a s UAV without a propulsion system), there is no relief from the requirements of the test flight

. I f a glider sUAV is proposed, the test flight shall still be conducted and submitted for approval. The prop osed flight may require the installation of a propulsion system in order to meet the requirements of the test flight. The propulsion system shall be removed prior to the authorized f light during “Spaceport	America	and	STEM+C	Flight	Series ”. 5. The test flight will abide by all rules and guidelines provided by the FAA’s “Know	before	you	fly”	requirements. http://knowbeforeyoufly.org/ 6. All sUAV’s used for the intent of this event shall be registered with the FAA following the prescribed guidelines using the following registration number: **FA 3KLHCMX7** 17



### 14 **C.F.R. §91.405**  **(a); 91.407**  **(a) (1);**  **91.409(a) (2);**  **91.417(a) &**  **(b): Maintenance**  **Inspections** These regulations require 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...,” and others shall inspect or maintain	the	aircraft	in	compliance	with	Part 43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the Petitioner. Maintenance will be accomplished by the Operator or manufacturer pursuant to the flight manual and operating handbook as provided by the various systems component manufacturers whos’ parts and components are used in construction of the authorized teams sUAS/sUAV

. An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in defined areas for limited periods of time. The Operator and manufacturer are most familiar with	the	aircraft	and	best	suited	to	maintain	the	aircraft	in	an	airworthy	condition	to provide the equivalent level of safety. The FAA has granted exemptions for similar operations in Exemptions 11062 through 11067, 11080 and 11110.

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## Federal **Register Publication**  Pursuant	to	14	C.F.R.	Part	11,	the following	summary	is	provided	for	publication	in the	Federal	Register,	should	it	be	determined	that	publication	is needed: STEM+C	Inc.	and	authorized	teams	are seeking	this	exemption	in	the	pursuit	of advancing	a	new	generation	of	science	and	math	literacy.		The	nature	of	““Spaceport America	and	STEM+C	Flight	Series”	event	necessitates	the	authorization	of	an exemption.		The	geographical	area,	date	and	time	would	be	limited	by	the	exemption. After	expiration	of	the	authorization,	no	further	authorization would	exist.		Any	of	the applied	for	and	approved	authorizations	would	need	to	be	re

-authorized	by	the administrator. Petitioner seeks an exemption from the following rules: 14 C.F.R. §§ 61.113(a) & (b); 91.7(a); 91.119; 91.121; 91.151(a); 91.405(a); 91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate non- commercially a small	unmanned	vehicle	(55	lbs.	or	less)	for	the	following	purposes:.18



## Summary I	thank	the	administrator	in	advance,	and	look	forward	to	approval	of	the	requested exemption. Please	do	not	hesitate	to	request	any	additional	information.		I	feel	this	event	can safely	take	place	at	the	applied	for	date,	time,	and	location. Thank	you, Paul	Kaup CEO	STEM+C	Inc. prkaup@gmail.com cell (708)	359	5289