The Aviation Law Firm

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, MD 21401

1-877-4-AIR-LAW  301-294-8550 

866-568-9886 fax

301-294-2525 fax

www.TheAviationLawFirm.com

Gregory S. Winton, Esq.

Admitted 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 REGULATIONS.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 Petition for 

Exemption, in which Woolpert seeks 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 will serve as a response to the Request for Additional Information received from 

Jake J. Troutman, Program Analyst, Federal Aviation Administration, Office of Aviation Safety, Airmen and 

Airspace Rules Division.

As requested, the information contained herein is intended to assist the Federal Aviation Administration with 

the evaluation of Woolpert’s Petition for Exemption. Pursuant to Mr. Troutman’s instructions, this information 

has been submitted 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 

proposed 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. To 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-2014-0398

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 (autopilot 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 Manual 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 provided as Exhibit A, and is to be held in a separate file pursuant 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 information 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 loss 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 times to monitor the airframe throughout the flight 

operation. Please 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. In accordance with 14 C.F.R. § 11.35(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 station and its operation.

Response:

Please see the Nova Block III/F6500 Operator Manual at Chapter 2, pages 2-10 through 2-16, for a 

complete description of the UAS ground control station (GCS) and its operation. Additionally please 

see the Nova Block III/F6500 Operator Manual 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. Winton

Gregory S. Winton

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

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