December 7 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition of Central Oregon Community College for exemption r equest under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

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, Central Oregon Community College (hereinafter referred to as "COCC " ) utilizing the 3DR Roboti cs Solo and Sense and fly Ebee AG small Unmanned Aircraft Systems (“sUAS”) seeks exemption from the requirements of Part 21 ; 14 C.F.R Sections 45.23(b), 61.113(a)& (b), 91.7(a); 91.9(b) ; 97.103; 91.109; 91.119; 91.121; 91.151(a)(1) ; 91.203(a)&(b) ; 91.405(a) ; 91.407(a)(1) ; 91.409(a)(1)&(a)(2) ; 91.417(a)&(b) ; of Title 14 CFR to operate an unmanned aircraft s ys tem (UAS) in accordance with Section 333 of the FAA Modernization and Reform Act of 2012. Th is exemption will permit COCC to operate a UAS for the purpos e of educational research and training.

IN TERESTS OF THE PETITIONER COCC is a p ublic community c ollege located in Bend , O regon

. COCC 's mission is to offer transfer and technical associate degree programs, certificate programs, and continuing education opp ortunities through a s ys tem of diverse resources and delivery alternatives. COCC also prepares today's workforce to meet the needs of a rapidl y changing, technologicall y advanced, global economy through traditional and nontraditional alternatives. COCC 's Aviation Department’s UAS b ranch is focused on providing practical, real

- world applications of UAS technologies through classroom instruction, cutting edge simulation training and hands

- on vehicle operations. To that end, COCC intends to use unmanned aircraft (UA) for educational research
, training, and data collection of UAS operational concepts and safety

. COCC seeks to operate its 3DR Robotics Solo, the Sense and Fl y Ebee AG UAS over the State of Oregon. Specifically , the 3DR Solo
, and the Sense and Fly Ebee UAS will be used to provide UAS education al concepts for students

. COCC will also have student’s building SUAS for recreational
, and experimental concepts. We understand there are no official FAA guidelines for S UAS education ; we are collaborating with industry to create a curriculum to meet current SUAS industry recommendations . COCC is seeking an exemption to sa fely introduce students to the broad range of UAS capability while reinforcing theory

taught in the classroom.

THE UAS 3DR Solo: A “s mart” quad copter built b y 3dr robotics has multiple features we like as an educational institution. Progressive controls, auto take off and land, return home features which make it a safe and affordable platform to train new operators on. Sense and Fl y Ebee AG: a small fixed wing platform with multiple payload options helps students understand the differences between VTOL and fixed wing operations.Both UAS are below 55 lbs including payload and are line of sight aircraft. Through the section

333 exempti on process the FAA has authorized the use of all UAS for which exemption is requested herein.

BASI S FOR PETITION Petitioner, CENTRALOREGON COMMUNITY COLLEGE, in accordance with the provisions of the Federal Aviation Regulations (14 CFR Section 11.61) and the FAA Modernization and Reform Act of 2012, Section 333, Special Rules for Certain Aircraft Systems, hereb y petitions the Administrator to operate the 3DR Solo and eBee AG UAS in the NAS, and for an exemption from the requirements of: 14 C.F.R. Part 21; 14 C.F.R. Part 43.3; 14 C.F.R. 45.23(b); 14 C.F.R. 113(a) & (b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.9(b) ; 14 C.F.R. 97.103; 14 C.F.R. 91.109; 14 C.F.R. 91.119; 14 C.F.R. 91.121; 14 C.F.R. 91.151(a)(1) ; 14 C.F.R. 91.203(a) & (b) ; 14 C.F.R. 91.405(a) ; 14 C.F.R. 91.407(a)(1) ; 14 C.F.R. 91.409(a)(1) & (a)(2) ; 14 C.F.R. 91.417(a) & (b) ;

In accordance with 14 C.F.R

. Section 11.81, COCC provides the following information in support of its petition for exemption:

NAME AND ADDRESS OF THE PETITIONER

The point of contact for this Petition and specific contact information is as follows: Karl Bald essari Aviation Program Director Central Oregon Community College 26 00 NW College Way Bend Or 9770 1 Phone 541.318.3702

OPERATI

NG PARAMETERS

COCC will adhere to the following operating parameters when operating UAS pursuant to a grant of the requested exemption: 1. Operations wi ll be conducted using 3DR Robotics Solo, the Sense and Fly Ebee AG UAS2. The UAS operations will be limited to a speed , not to exceed 87 knots (100 miles per hour), at

an altitude no greater than 2 00 feet above ground level . When visibility is less than 3 statute miles, operations will not be conducted less than 500 feet below or 2,000 feet horizontally from cloud s . All operations will be conducted during the day under visual meteorological conditions. 3. All operations will be conducted in accordance with a Certificate of Waiver or Authorization ("COA ''). 4. All operations will use a pilot

- in

- command ("PIC") and a visual observer ("VO"), and the UAS will remain within the visual line of sight (VLOS) of the PI C or the VO at all times. The PI C will maintain VLOS capability and the ability

to communicate verbally with the VO at all times. 5. The PI C will hold an airline transp ort, commercial, private, recreational, or sport pilot

ce rtificate, as well as an FAA air man medical certificate or a valid U.S. driver 's license. The PI C will meet the flight review requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 6. COCC wil l i nsure the PI C has demonstrated the ability to safel y operate the UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles an d struc tures. PIC qualification flight hours and currency

will be logged in a m ann er consistent with 14 C. F.R. § 61.51(b). 7. COCC’s operating documents will be accessible during UAS operations and made available to the Administrator upon request. 8. Prior to each flight, the PI C will conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the UAS will not be operated until the necessary maintenance has been performed and the U AS is found to be in a condition for safe flight. 9. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, will undergo a functional test flight prior to conducting further operations under this exemption. 10. COCC will follow the UAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements, as well as safety bulletins, for the aircraft and aircraft components. 11. The PI C will abort the fl ight in the event of unpredicted obstacles or eme rgencies, and will yield to all manned aviation activities. 12. COCC will register and mark its UAS in accordance with 14 C.P.R. parts 47 and 45.

**The Specific Sections Of 14 C.F.R.**  **From Which COCC Seeks Exemption & Extent COCC seeks Relief** 

 **14 C.F.R. § 45.23(b)** 

**– Aircraft Marking and Identification**   Requirements states: Wh en 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 certi ficated 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.

The sUAS to be flown by COCC have no airworthiness certificate. An exemption may be needed as the sUAS have no entrance to the cabin, cockpit, or pilot station on which the word “Experimental” can be placed. The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A

.

 **14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations**  **Sections 61.113(a) and (b)** limits private pilots to noncommercial operations.

Bec ause the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PI C operating the aircraft to have a private pilot’s license rather than a commercial pilot’s lice nse to operate a sUAS. Unlike a conventional manned aircraft, a sUAS is remotel y controlled by a ground

- based operator. The operational area is controlled and restricted, and all flights are planned and coordinated in advance. The level of safety exceeds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the use of a sUAS

are so diminished from the level of risk associated with commercial operations contemplated by Part 61 allowing sUAS use by a private pilot as the PI C exceeds the pres ent level of safety sought b y 14 C.F.R. §61.113 (a) and (b).

 **14 C.F.R. 91.7(a)**

**– Civil Aircraft Airworthiness:**   No person may operate a civil aircraft unless it is in an airworthy condition.

There is no airworthiness certificate for the sUAS to be operated b y A dvanced Robotics. To provide an equivalent level of safety, the PIC will conduct pre

- flight inspections to ensure airworthiness. During flight, the PIC will adhere to § 91.7(b) and abort air operations immediately

upon identification of an in

- flight anomaly or emergency

. Licensed A&P staff will conduct annual inspections. Maintenance log books will be maintained for each sUAS thereby achieving an equival ent level of safety.

 **14 C.F.R. § 91.9 (b)** (2): **Civil Aircraft Flight Manual in the Aircraft.**  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.

The sUAS, given their size and configuration have no ability or place to carry

such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity

to carry such an item on the aircraft platform. The equivalent level of safety will be maintained by

keeping the sUAS documentation at the ground control point where the PIC will have access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700. **14 C.F.R. 91.103**

**– Pre** 

**- flight Ac**  **tion:**

 Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

- (paragraphs a, b, 1 and 2)

The PI C will take all actions, to include flight and mission planning, reviewing weather, flight battery requirements, safe take

- off and landing areas, and aircraft performance data before commencement of flight. In addition, the PI C will verify the sUAS is ready

for flight b y conducting a pre

- flight inspection and run up of s ystems and data

- link communications checks prior to each flight. The exemption requested for this section is specificall y addressed toward the requirements which do not apply to sUAS operations such as runway s and air traffic control integration . The airport manager will be notified and approval obtained prior to any operations being executed less than five statute miles of an operating airport

.

 **14 C.F.R. §91.109: Flight instruction:**  Section 91.109 provides that 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.

sUAS and remotel y piloted aircraft, b y their design do not have fully functional dual controls. Flight control is acco mplished through the use of a radio transmitter or ground control station that communicates with the aircraft via a receiver in the sUAS. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft an d for flight instruction in experimental aircraft. See Exemption numbers 5778K & 9862A. The equivalent level of safety provided b y the fact that neither a pilot nor passengers will be occupants in the aircraft and by the small size and slow speed of the sUAS.

 **14 C.F.R. 91.119**

**– Minimum Safe Altitudes:**   Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (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.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. This exemption is for a sUAS and the exemption requests authority to operate at altitudes up to 500 AGL underneath navig able airspace and in class E and G airspace maintaining safe separation from manned aircraft, an exemption may be needed to allow such operations. The equivalent level of safety

will be achieved given the size, weight, speed of the sUAS as well as the limi ted and controlled location where it is operated. Compared to flight operations with manned aircraft weighing far more than the maximum 55 pounds proposed herein, and the lack of flammable fuel, an y risk associated with these operations is far less than th ose presently presented with conventional manned aircraft. In addition, the low

- altitude operations of the sUAS will ensureseparation between it and operations of conventional manned aircraft that must comply with Section 91.119.

 **14 C.F.R. §91.121 Altime ter Settings:**   This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "... to the elevation of the departure airport or an appropriate altimeter setting available before departure."

As the sUAS do not have an adjustable barometric altimeter an exemption is required. An equivalent level of safety will be achieved by the PI C , confirming the altitude of the launch site via the sUAS GPS

 **14 C.F.R §**  **91.151(a)(1):**  Fuel requirements for flight in VFR conditions, subsection (a)(1), states the following: (a

) No person may begin a flight in an airplane under VFR conditions unless (considering wind 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

This regulation is written based on the capabilities of a traditional aircraft which have flight times of several hours or greater; therefore, with the majority of sUAS which have flight times of only an hour or less, this regulation would effectively deny the ability

of the air vehicle to operate. With this regulation the flight time duration of the battery powered 3DR Robotics Solo
, the Sense and Fly

Ebee AG will be reduced b y one third, which would severel y constrain the practicality of an y educational research and training operations that COCC proposes to conduct as requested in this petition. F lights of the battery

powered 3DR Rob otics Solo , the Sense and Fly Ebee AG during daylight hours under visual flight rules (VFR) in visual meteorological conditions (VMC) to continue for a total duration of 90 minutes, or until 20% battery power is remaining (whichever occurs first). Signific antl y, the technical specifications of the 3DR Robotics Solo , the Sense and Fl y Ebee AG operators manuals , and COCC 's proposed operating limitations ensure that COCC will safely operate the battery

powered 3DR Robotics Solo , the Sense and Fl y Ebee AG durin g daylight hours under day

VFR in VMC for a total duration of 90 minutes, or until 20% battery power is remaining, whichever occurs first

. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

 **14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration:**   The regulation provides in pertinent part: (a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropria te and current airworthiness certificate....(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpi t entrance so that it is legible to passengers or crew

. The sUAS fully

loaded weighs no more than 55 lbs. and is operated without an onboard pilot. As such, there is no ability

or place to carry certification and registration documents or to displaythem on the sUAS. An equivalent level of safety will be achieved b y keeping these documents at

the ground control point where the PIC will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to th is regulation. A representative sample of other exceptions includes Exemption numbers 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

 **14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b)**

**– Maintenance**  **Inspections:**  **91.405(a) States:** Each owner or operator of an aircraft

— (a ) 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 pa rt 43 of this chapter.  **91.407(a)(1) States:** (a ) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1 ) It has been approved for return to service by a person authorized under § 43.7 o f this chapter.  **91.409(a)(2) States:** (a ) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

— (2 ) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an ‘‘annual’’ inspection in the required maintenance records.  **91.417(a) & (b) States:** (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (paragraphs 1 (i

– iii), 2 (i

– vi)); (b) The owner or operator shall retain the following records for the periods prescribed: (paragraphs 1

– 3)

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) &(b) onl y apply to aircraft with an air worthiness certificate, COCC requests relief from these Sections because the 3DR Solo UAS does not require an airworthiness certificate. The 3DR Robotics Solo , the Sense and Fl y Ebee AG UAS meet s the conditions of Section 333 for operation without an air

worthiness certificate. Pre

- flight inspections and routine maintenance will be accomplished by the PI C to ensure the sUAS is in good working order prior to flight. If mechanical issues or
emergen cy

situations arise the sUAS can land immediately and given its small size poses very little risk to persons or property . Upon completion of any repair, modification or upgrade, the aircraft is test flown b y a qualified PI C and documented within the mainte nance log book prior to return to service. Annual inspections and maintenance will be conducted and documented within the sUAS maintenance log book b y licensed A&P personnel to meet the intent of these regulations and provide an equivalent level of safety

. Furthermore, COCC will document and maintain all maintenance records for the 3DR Solo UAS. Since we are requesting relief from these sections, Section 91.203 (a) and (b), 45.23 (b), 21.185 and 91.9(b) also would not apply

. **The Reasons Why Granting COCC's Request Would Be In The Public Interest** 

How It W ould Benefit The Public As a Whole.Granting COCC 's request for a waiver will further the public interest by allowing COCC to safel y, efficientl y, and economically perform UAS educational research and pilot in command training

. Additionall y, use of the 3DR Solo UAS will provide significant benefits to the

econom y b y allowing additional training opportunities and further the collection of safety data. The data collected would help further the FAA goals of integrating UAS into the NAS without reducing existing capacity , decreasing safety
, negative impacting current operators, or increasing the risk to airspace users or persons and property on the ground an y more than the integration of comparable new and novel technologies, through this collaboration. Additionally , the benefits of the proposed operation of the 3DR Robotics Solo , the Sense and Fly Ebee AG UAS will be realized without implicating any privacy issues. 1. T he Public will benefit from properl y trained UAS operators and safe UAS operations COCC submits this Petition to perform UAS educational research and training in the areas of pilot education and SUAS operational research

. The multi

- campus college is located in Bend Oregon. 2. The Public wil l b ene fit f rom increased UAS operator trainin g w ithin the NAS. The mission of COCC 's Aviation Department is the training of a viable workforce for the community

with the skills necessary for future achievement. COCC 's UAS degree program
, provides practical , real

- world applications of UAS technologies through classroom instruction, cutting

- edge simulation training and hands on vehicle operations. By operating the 3DR Robotics Solo , the Sense and Fly Ebee AG UAS, COCC will be able to perform safe, efficient, a nd economical aerial educational operations directly benefit ing the public

. 3. UAS Will Benefit The Econom y. In addition to being safe and efficient, the 3DR Solo UAS is also an economical alternative to using manned aircraft to conduct aerial educational research and training. As such, operation of the 3DR Solo UAS will allow United States based companies to remain competitive and contribute to growth of the U.S. econom y. Educational institutions, like COCC , will benefit by remaining relevant and on the leading edge of technology advances in UAS

. Operating the battery powered 3DR Robotics Solo , the Sense and Fly Ebee AG UAS allows COCC greater operational flexibility
, with efficient costs. Students become employable with applicable UAS skills and operati onal UAS safety education. 4. There Are No Privacy

I ssues. The 3DR Solo will be operated in a safe privacy focused curriculum where Students learn the laws and rights to privacy The Reasons Why

Granting The Exemption Would Not Adversel y Affect Safety Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which COCC Seeks Exemption. 1. Reasons Why 3DR Robotics Solo , the Sense and Fly Ebee AG UAS Meet The Conditions Of The FAA Modernization and Reform Act of 2 012 (FMRA) Section 333. In consideration of the size, weight, speed, and limited operating area associated with the UA and its operation, COCC 's operation of the 3DR Robotics Solo , the Sense and Fl y Ebee AG UAS meets the conditions of FMRA Section 333, an d will not require an airworthiness certificate in accordance with 14 CFR Part 21, Subpart H. Section 333 provides authority for UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a haza rd to users of the NASor the public, or otherwise pose a threat to national security . Specificall y, FMRA Section 333

states the following, in part: (a ) In General.

--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by Section 332 of this Act or t he guidance required by Section 334 of this Act. (b ) Assessment of Unmanned Aircraft Systems.

--In making the determination under subsection (a ), the Secretary shall determine, at a minimum

-- (1 ) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and (2 ) whether a certificate of waiver, certificate of authorization, or airworthiness certification under Section 44704 of Title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for

- the safe operation of such aircraft systems in the national airspace system. Although a degradation or loss of the control link, and/or degradation or loss of the source of navigation, is unlikely , it is a situation that is well planned for and therefore, is a benign event. The 3DR Robotics Solo , the Sense and Fl y Ebee AG UA S are designed for complete autonom y from launch to landing with a line of sight operator in the loop monitoring the airframe. pursuant to 14 CFR Section 11.35(b). Furthermore, all flight operations will be conducted in ac cordance with 14 CFR Section 91.119, Minimum safe altitudes: General.

Likewise, as set forth above, COCC has proposed specific operating limitations in this Petition that will maintain the level of safety established by Section 91.151(a)(1), including the following: (1) the 3DR Robotics Solo , the Sense and Fly Ebee AG will only be operated during daylight ho urs (i.e. between the end of morning civil twilight and the beginning of evening civil twilight, as published in the American Air Almanac, converted to local time); (2) Nova F6500 UA will only

be operated pursuant to day VFR in VMC; and (3) the duration of each flight shall not exceed 90 minutes or 20% of battery life remaining, whichever occurs first. Significantl y, previous exemptions granted b y the FAA concerning Section 91.151(a)(1) establish that safety is not adversel y affected when the technical char acteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151(a), including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previou sl y granted relief from Section 91.151(a)(1), specific to UAS, in circumstances similar to those presented here (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080). 3. Reasons Why

An Exemption From The Requireme nts Of Sections 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b) Would Not Adversel y Affect Safety

.In seeking this exemption, COCC submits that the level of safety with regard to the

regulatory

maintenance and alteration req uirements established by

Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), 91.417(a) &(b) will be met because COCC , as operator of the 3DR Robotics Solo , the Sense and Fl y Ebee AG UAS, will use its trained technicians to perform maintenance, alterati ons, or preventive maintenance on the UAS using the methods, techniques, and practices prescribed in the manufacturer's maintenance manual, as it does today within the procedures set forth in its existing COAs. Furthermore, COCC will document and maintain all maintenance records for the 3DR Robotics Solo , the Sense and Fly Ebee AG UAS. Since the 3DR Robotics Solo , the Sense and Fl y Ebee AG will be inspected as prescribed by the manufacturer's maintenance manual, COCC will maintain the level of safety establ ished by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The Nova F6500 Maintenance Manual sets forth Scheduled Maintenance Inspection procedures for each s ys tem and component. Inspection intervals for the 3DR Robotics Solo , the Sense and Fl y Ebee AG UAS include preflight and post flight inspections, as well as scheduled inspections every 25 hours, 50 hours, 75 hours, and 100 hours. Likewise, the exemption sought will not adversel y affect safety because COCC will perform maintenance, alterations or prev entive maintenance on the UAS using the methods, techniques, and practices prescribed b y the manufacturer's maintenance manual. The 3DR Robotics Solo , the Sense and Fl y Ebee AG Maintenance Manual s detail procedures for each component of the UA, including the components of the propulsion sy stem, avionics sy stem, payload system, fuselage sy stem, wing, and tail. Significantl y, previous exemptions granted b y the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), 91.417(a) &(b) establish that safety is not adversel y affected when the technical characteristics and operating limitations of a UAS are considered. 4. The FAA May

Prescribe Any

Other Conditions For Safe Operation. In accordance with FMRA Section 333 and 14 CFR Section 21.16 entitled Special Conditions, COCC requests that the FAA prescribe special conditions for the intended operation of 3DR Robotics Solo , the Sense and Fl y Ebee AG UAS, which contain such safety standards that the Administrator finds necessary to establish a level of s afety equivalent to that established by 14 CFR Part 21, Subpart H, and 14 CFR Sections 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) &(a)(2), and 91.417(a) &(b). Such special conditions will permit safe operation of the UA for the limited purpose of educational research and training. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security ; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the aircraft s ys tems in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 CFR Section 21.16, for operation of the 3DR Robotics Solo , the Sense and Fl y Ebee AG UAS, since the airworthiness regulations of 14 CFR Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft . Section 21.16, entitled Therefore, in accordance with FMRA Section 333 and 14 CFR Section 21.16, the FAA
may prescribe special conditions for Sinelair's intended operation of the 3DR Robotics Solo , the Sense and Fl y Ebee AG , which contain such safety st andards that the Administrator finds
necessary to establish a level of safety equivalent to that established by 14 CFR Part 21, Subpart 11. F.