# The Aviation Law Firm

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Annapolis, MD 21401

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www.TheAviationLawFirm.com Gregory S. Winton, Esq.

Ad mitted in MD, NY, PA, CT, and D.C.

greg@aviationlawexperts.com

Jared M. Allen, Esq.*

*Admitted in FL and D.C. Only

jallen@aviationlawexperts.com

October 23 , 2014

VIA ELECTRONIC MAIL : rob.pappas@faa.gov

AND REGULATION S.GOV (w/o proprietary information as per 14 C.F.R. § 11.35 )

Robert A. Pappas UAS Integration Office

Federal Aviation Administration

490 L 'Enfant Plaza, S.W.

Suite 3200 Washington, DC 20024

RE: Request for Additional Information: Woolpert, Inc., Docket No . FAA

- 2014

- 0398

Dear Mr. Pappas:

As you are aware, this office represents Woolpert, Inc. (“Woolpert”) regarding the above

- referenced P etition for

E xemption

, in which Woolpert seek s regulatory relief to operate an unmanned aircraft system (UAS ) for the purpose of conducting aerial acquisitions over certain rural areas located on Ship Island , MS (Docket No.

FAA

- 2014

- 0398)

. This letter w ill serve as a response to the Request for Additional Information received from Jake J. Troutman, Program Analyst, F ederal Aviation Administration, Office of Aviation Safety

, Airmen and Airspace Rules Division

.

As requested, t he information contained here in is intended to assist the Federal Aviation Administration with

the evaluation of Woolpert’s P etition for Exemption

. Pursuant to Mr. Troutman’s instructions, th is information

has been submit ted to www.regulations.gov with the docket number shown above. Additionally, any proprietary information has been submitted via e

- mail to jake.troutman@faa.gov

.

Kindly consider the following responses to each Request for Additional Information concerning Woolpert’s

prop osed operation of the Nova Block III (also known as the Nova F6500 UAS ) (hereinafter referred to as the

“Nova Block III / F6500 UAS ”) :

Request for Additional Information:

1. T o assist with our assessment of Woolpert’s petition for exemption from 14 C .F.R. § 91.9(b)(2), please provide a copy of your UAS Flight Manual that addresses specific instructions, limitations, checklists, and other information, if any, necessary to operate the Nova Block III UAS safely.Re: Woolpert, Inc.

Docket No . FAA

- 201 4

- 0398

October 23 , 2014 Page 2

Response:

A copy of the Nova Block III/ F6500 UAS Operator Manual, which contains proprietary information, has been provided as Exhibit A, and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b) 1

.

Request for Additional Information:

2. To assist with our assessment of Woolpert’s petition for exemption from 14 CFR part 21, please describe (this information may be included within the UAS Flight Manual or similar document):

a. Any automatic flight modes (au topilot functions) and methods of navigation (GPS, visual, etc.) for the Nova Block III UAS and how those and other features, if any, enable the UAS to remain within a defined operational area. Response:

Please see the Nova Block III/ F6500 UAS Operator Ma nual at pages 7

- 2 through 7

- 4 for a complete description of the automatic flight modes and methods of navigation for the Nova Block III/ F6500 UAS

. A copy of the Nova Block III/ F6500 UAS Operator Manual, which contains proprietary information, has been pro vided as Exhibit A , and is to be held in a separate file p ursuant to 14 C.F.R. § 11.35(b)

.

Request for Additional Information:

2. To assist with our assessment of Woolpert’s petition for exemption from 14 CFR part 21, please describe (this informat ion may be included within the UAS Flight Manual or similar document):

b. How the UAS responds to degradation or loss of the control link (lost

- link response) and or degradation or loss of the source of navigation. Response:

Although a degradation or loss of the control link, and/or degradation or l oss of the source of navigation

is highly unlikely, it is a situation that has been adequately designed into the UAS. Therefore, such an

occurrence would result in a nonthreatening event . Specifically

, the Nova Block III/ F6500 UAS is designed for complete autonomy from launch to landing

. Moreover, an operator (i.e., pilot

- in

- command) remains present and within the line of site at all time s to monitor the airframe throughout the flight operation. P lease review the Nova Block III/ F6500 UAS Operator Manual at Chapter 9 for a complete description of how the UAS will respond to an unlikely event involving a power loss, loss of communications, loss of GPS navigation , loss of video link, or software crash. A copy of the Nova

Block III /F6500 Operator Manual, which contains proprietary information, has been provided as Exhibit

A , and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b)

.

1 Exhibits provided herewith contain proprietary information

. I n accord ance with 14 C.F.R. § 1 1.35(b), proprietary information is not to be placed in the Federal Docket Management System (FDMS).Re: Woolpert, Inc., Docket No . FAA

- 2014

- 0398

October 23 , 2014 Page 3

Request for Additional Information:

2. To assist with our assessment of Woolpert’s petition for exemption from 14 CFR part 21, please describe (this information may be included within the UAS Flight Manual or similar document):

c. The control stati on and its operation. Response:

Ple ase see the Nova Block III/F6500 Operator Manual at Chapter 2, pages 2

- 10 through 2

- 16, for a complete description of the UAS g round control station (GCS) and its operation . Additionally please

see the Nova Block III/F6 500 Operator Manua l at chapter 7 for a complete description of the features and operation of the GCS software. A copy of the Nova Block III/F6500 Operator Manual, which

contains proprietary information, has been provided as Exhibit A , and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b)

.

If you have any further questions or require additional information, please do not hesitate to contact me.

Thank you for your consideration of this matter.

Respectfully submitted,

/s/ Gregory S. Wint on

Gregory S. Winton

cc: Jake J. Troutman ( Jake.Troutman@faa.gov )

James Williams (james.h.williams@faa.gov)