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 request 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 Robotics 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 system 

(UAS) in accordance with Section 333 of the FAA Modernization and Reform Act of 2012. This 

exemption will permit COCC to operate a UAS for the purpose of educational research and 

training.

INTERESTS OF THE PETITIONER

COCC is a public community college located in Bend, Oregon. COCC's mission is to 

offer transfer and technical associate degree programs, certificate programs, and continuing 

education opportunities through a system of diverse resources and delivery alternatives. COCC

also prepares today's workforce to meet the needs of a rapidly changing, technologically 

advanced, global economy through traditional and nontraditional alternatives. COCC's Aviation 

Department’s UAS branch 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 Fly 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 educational 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 SUAS education; we are collaborating with industry to create a curriculum to meet current 

SUAS industry recommendations. COCC is seeking an exemption to safely introduce students 

to the broad range of UAS capability while reinforcing theory taught in the classroom. 

THE UAS

3DR Solo: A “smart” quad copter built by 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 Fly 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 exemption process the FAA has authorized the use of all UAS for which exemption is 

requested herein. 

BASIS FOR PETITION

Petitioner, CENTRAL OREGON 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, 

hereby 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 Baldessari

Aviation Program Director

Central Oregon Community College

2600 NW College Way

Bend Or 97701

Phone 541.318.3702

OPERATING PARAMETERS

COCC will adhere to the following operating parameters when operating UAS pursuant

to a grant of the requested exemption:

1. Operations will be conducted using 3DR Robotics Solo, the Sense and Fly Ebee AG UAS
2. The UAS operations will be limited to a speed, not to exceed 87 knots (100 miles per hour), at 

an altitude no greater than 200 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 

clouds. 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 PIC or the VO at all times. The

PIC will maintain VLOS capability and the ability to communicate verbally with the VO

at all times.

5. The PIC will hold an airline transport, commercial, private, recreational, or sport pilot

certificate, as well as an FAA airman medical certificate or a valid U.S. driver's license.

The PIC 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 will insure the PIC has demonstrated the ability to safely operate the UAS in a manner

consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight 

hours and currency will be logged in a manner 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 PIC 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 PIC will abort the flight in the event of unpredicted obstacles or emergencies, 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: 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.

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.

Because 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 PIC operating the aircraft to have 

a private pilot’s license rather than a commercial pilot’s license to operate a sUAS. Unlike a 

conventional manned aircraft, a sUAS is remotely 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 PIC exceeds the present level of safety 

sought by 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 by Advanced 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 equivalent 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 Action:

 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 PIC 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 PIC will verify the sUAS is ready for flight by

conducting a pre-flight inspection and run up of systems and data-link communications checks 

prior to each flight. The exemption requested for this section is specifically addressed toward the 

requirements which do not apply to sUAS operations such as runways 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 remotely piloted aircraft, by their design do not have fully functional dual controls. 

Flight control is accomplished 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 and 

for flight instruction in experimental aircraft. See Exemption numbers 5778K & 9862A. The 

equivalent level of safety provided by 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 navigable 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 limited 

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, any risk associated with these operations is far less than those presently presented with

conventional manned aircraft. In addition, the low-altitude operations of the sUAS will ensure 
separation between it and operations of conventional manned aircraft that must comply with 

Section 91.119.

 14 C.F.R. §91.121 Altimeter 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 PIC, 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 by one third, which would severely constrain the 

practicality of any educational research and training operations that COCC proposes to conduct 

as requested in this petition.

Flights of the battery powered3DR Robotics 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).

Significantly, the technical specifications of the 3DR Robotics Solo, the Sense and Fly 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 Fly Ebee AG during 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 

appropriate 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 cockpit 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 display
them on the sUAS. An equivalent level of safety will be achieved by 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 this 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 part 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 of 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) only 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 Fly Ebee AG UAS meets the conditions of Section 333 for operation without an airworthiness certificate. Pre-flight inspections and routine maintenance will be accomplished by

the PIC to ensure the sUAS is in good working order prior to flight. If mechanical issues or 

emergency 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 by a qualified PIC and documented within the maintenance log book prior to 

return to service. Annual inspections and maintenance will be conducted and documented within 

the sUAS maintenance log book by 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 Would Benefit The Public As a Whole.
Granting COCC's request for a waiver will further the public interest by allowing COCC to 

safely, efficiently, and economically perform UAS educational research and pilot in command 

training. Additionally, use of the 3DR Solo UAS will provide significant benefits to the 

economy by 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 any 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. The Public will benefit from properly 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 will benefit from increased UAS operator training within 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 the3DR Robotics Solo, the Sense and Fly Ebee AG UAS, COCC will be 

able to perform safe, efficient, and economical aerial educational operations directly benefiting

the public.

3. UAS Will Benefit The Economy.

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. economy. 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 operational UAS safety 

education. 

4. There Are No Privacy Issues.

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 Adversely 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 2012 (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 Fly Ebee AG

UAS meets the conditions of FMRA Section 333, and 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 hazard to users of the NAS 
or the public, or otherwise pose a threat to national security. Specifically, 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 the 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 Fly Ebee AG UAS are designed for 

complete autonomy 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 accordance 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 hours (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.

Significantly, previous exemptions granted by the FAA concerning Section 91.151(a)(1) 

establish that safety is not adversely affected when the technical characteristics 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 previously 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 Requirements 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 Adversely Affect 

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

regulatory maintenance and alteration requirements 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 Fly Ebee AG UAS, will use its trained technicians to 

perform maintenance, alterations, 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 Fly Ebee AG will be inspected as prescribed 

by the manufacturer's maintenance manual, COCC will maintain the level of safety established 

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 system and component. 

Inspection intervals for the 3DR Robotics Solo, the Sense and Fly 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 adversely affect safety because COCC will 

perform maintenance, alterations or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed by the manufacturer's maintenance manual. The 3DR 

Robotics Solo, the Sense and Fly Ebee AG Maintenance Manuals detail procedures for each 

component of the UA, including the components of the propulsion system, avionics system, 

payload system, fuselage system, wing, and tail.

Significantly, previous exemptions granted by 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 adversely 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 Fly Ebee AG UAS, which contain such safety standards 

that the Administrator finds necessary to establish a level of safety 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 systems 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 Fly 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 Fly Ebee AG, which contain such safety standards that the Administrator finds 

necessary to establish a level of safety equivalent to that established by 14 CFR Part 21, Subpart 

11. F.