## PETITION OF:
MIAMI DADE COLLEGE Eig-Watson School of Aviation

Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012

### INDEX

I. Introduction 2


### II. Petitioner 3


### III

. Proposed Operations 4


### IV. Program Activities 

### 5
V. Exemption Requested 5


### VI. DJI Phantom 2 UAS Vehicle Description 11


### VII

. Airworthiness ofDJI Phantom 2 UAS 13


### VIII. Training 13


### IX. Safety 13


### X

. Operating Conditions 

### 14
XI. Pre-Flight Checklist 17


### XII. Post-Flight Checklist 17


### XIII. Public Interest 17


### XIV. Privacy 

### 18

1I. INTRODUCTION
Miami Dade College (MDC) is an institution ofhigher education, accredited by the Southern Association ofColleges and Schools Commission on Colleges (SACSCOC). The MDC operates its flight programs through the Eig

-Watson School ofAviation (School).Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 ("Reform Act") and 14 C.F.R. Part 11, MDC hereby applies for an exemption from the Federal Aviation Regulations (FARs) identified below to allow for the non-hobby operation ofsmall unmanned aerial vehicles (UAS) as part of School's flight education programs. This exemption is based specifically on information outlined in this petition and such information contained in the Phantom 2 UAS Flight Operation Manual, and its manufacturer user manual, which includes the specifications ofthe UAS equipment, the Phantom 2 UAS Aircraft Flight Manual, the User Manual, the Smart Flight Battery Safety Guidelines, the Quick Start Guide, and Remote Training Control Manual. The new remote control unit to be utilized in these operations is compatible with the Phantom 2 Vision+, Phantom 2 Vision unite. MDC is proposing to offer educational courses that includes UAS ground and flight training as continuing education noncredit courses. These non-credit courses offerings may be expanded to such UAS, related subjects as aerodynamics, commercial uses, safety, and maintenance. MDC will further explore the possibility ofenhancing their academic program by offeringvarious courses in UAS ground and flight training for other commercial /nonmilitary industries to include video/photographic, agricultural, real estate, law enforcement/security, engineering, and architectural industries. The intent is to develop such educational training courses which would enable MDC to become an educational center for providing a formalized training program in UAS subjects, to both the public and private sector industries listed above. MDC also intends to deliver web-based online courses and deliver instructions in UAS ground and flight training to students within and outside the South Florida area. The School has the infrastructure to include the physical location ofclassrooms from its campuses serving the Miami

-Dade County area, as well as, its academic network to include its faculty, adjunct faculties, administration, and the organization as part ofits overall educational program.



### 2II. Petitioner MDC has been in existence in the South Florida area since its initiation as a community college in 1960 and has provided college education while serving the community as a higher-level two-year educational institution. MDC has eight campuses and twenty-one outreach centers with over 165,000 students, making it the largest learning institution in the State ofFlorida. MDC has been recognized as one of the best community college in the United States. The School began in the 1960s and has a rich history in delivering aviation flight education to successful graduates who have served in both the public and private sector in aviation. The School has trained civilian pilots and aviation students by offering them various technical degrees in such credit programs as Professional Pilot, Maintenance, Aviation Administration, and A irTraffic Control. M DC has also been the forefront oftraining successf ul candidates that have continued their education in such institutions such as EmbryRiddle Aeronautical University and George T. Baker Maintenance School. MDC students have been employed with major airlines throughout the United 

### States, and within numerous parts ofgovernmental agencies having oversight over commercial aviation in the United States. MDC is dedicated to building a well developed educational program and it's visionary aviation and aerospace programs, that fosters aviation education in the Sout h Florida area.

In accordance with 1 4 C.F.R. 11.81 (a), the MDC the contact information for the Petitioner is:

Thomas Jargiello D

irector Miami Dade College Eig-Watson School ofAviation 500 College Terrace Homestead, Florida 33030-6009 Phone# (305) 237-5080 Fax# (305) 237-5956 Web: www.mdc.edu Email: tjargiel@mdc.edu

3

### III. Proposed Operations MDC is proposing to begin an educational VAS flight instruction program. This program will teach students the essential elements ofVAS operations from a commercial and non-commercial perspective, and the overall aspect ofoperating an VAS within our current airspace. Our initial course would teach the history ofVAS from its beginning stages ofbeing used in military flight operations, to its transition into civilian use. This training will include an analysis ofhow these operations pertain to our National Airspace System (NAS). MDC is presently providing ground training under a Part 141 Certificate for its Professional PilotTechnology program. This program has been in existence for several years and offers educational accredited courses for Private, Instrument and Commercial ratings, all ofwhich meet the regulatory standards ofa Part 141 approval program. MDC proposes to formally develop a VAS training curriculum that meets the academic standards established for the all educational courses within our institutional system. The present proposal offers a VAS ground training course in Phase 1. The VAS flight portion training course will be offered in Phase 2 and would be conducted only upon receipt ofthis requested exemption. The MDC offering ofa VAS educational training program is based on our current course outline thatwill meet safety considerations and regulatory compliance with our college level ofacademic standards. We would propose that our educational program can serve as a model for others to emulate and would serve as an invaluable FAA resource. The training will be conducted under strict operating requirements and conditions, to assured that the level ofsafety is maintained at the highest standard in authorizing operation ofUAS vehicles meeting FAA Section 333 standards. It is a fact that the sales ofVAS vehicles has been on the rise and continues to grow with numerous different VAS models being offered by a variety ofdifferent manufacturing companies. The new owners have the accessibility, not only to purchase the UAS, without any regulatory constraint, but in most cases the manufacturing models do not provide the adequate training and instructions to operate such equipment. It is also more alarming that UAS operations, by these new owners in our current airspace system, do not have an educational safety training program for these new VAS operations. All this suggests that a well established educational training curriculum in the safe operation ofthe VAS in our current airspace system is required. MDC's regional educational program in offering VAS trainingwould alleviate the current problem that new owners are facing, by offering an alternative program through an educational program, monitored and approved by the FAA. MDC intends to work under strict safety conditions coincidingwith the FAA's responsibilities under Section 333 (c) ofthe Reform Act to establish requirements for the safe operation ofsuch aircraft systems in the national airspace system.

4

### IV. Program Activities The School's educational program for the use for UAS devices will include the following: (1) Training sessions duringwhich School faculty will be trained in the operational and safety techniques for the use ofthe School's UAS devices. (2) Non-credit courses, addressing familiarization and safety subjects, dealing with the operation ofUAS devices. These courses would include a ground school section and a live flight section. (3) These courses will be offered through the MDC School ofContinuing Education

. (4) Additional non-credit UAS related courses dealing with such subjects as the aerodynamic operations ofUAS devices, advanced safety principles, commercial uses ofUAS devices, and maintenance ofUAS devices. (5) It is the School's intent to further develop this program to include credit courses related to UAS subjects, as well as, a college credit certificate program dealing with the fundamentals ofUAS operations, safety factors, flight aerodynamics, and commercial uses ofUAS equipment. 

### Exemption Requested Miami Dade College requests exemptions from the following regulations: 14 C.F.R. Part 21: (Aircraft certification requirements) 14 C.F.R 45.23 (b); ("N" numbers and markings) 14 C.F.R. 61. 11 3 (a) & (b); (Private pilots operating for hire) 14 C.F.R. 61.133; 14 C.F.R. 91.7 (a) & (b); 14 C.F.R. 91.9 (b); 14 C.F.R. 91.103 14 C.F.R. 91.109 (a); 14 C.F.R. 91.1 1 9;14; 14 C.F.R. 9 1.1 21; 14 C.F.R. 91.151 (a); 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)(2); 14 C.F.R. 91.417 (a); (Commercial pilots as related to above) (Civil aircraft airworthiness) (Civil aircraft flight manual, marking and placard requirements) PreFlightAction (Dual controls for instruction) (Safe altitudes over obstacles) (Altimeter setting) (Fuel minimum) (Maintenance inspections) (Maintenance related) (Maintenance related) (Airworthy certificates) (Maintenance record keeping)

5Additional information to support the requested exemption is as follows: 

### (a) 14 C.F.R. Part 21, Subpart H. Airworthiness Certif icates 14 C.F.R. 9 1.203 

### (a) ( 1) Subpart H, Entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR 91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements ofan equivalent level of safety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 U.S.C. 44701 (f)) and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed operational capability, and proximity to airports and populated areas ofthe particular UAS

. In all cases, an analysis ofthese criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed. The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured and designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by both the operator and underthe requirements and in compliance with local public safety requirements. The FAA will have advance notice ofall operations. These safety enhancements provide a greater degree of saf ety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application ofthese same criteria demonstrates that there is no credible threat to national security posed by the UAS, due to its size, speed ofoperation, location ofoperation, lack ofexplosive materials offlammable liquid fuels, and inability to carry a substantial external load. 

### (b) 14 C.F.R. 4 5.23 (b) M arking ofthe Aircraft The regulation requires that Aircraft marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

-sport 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 no less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light sport", "experimental," or "provisional," as applicable. Even though the VAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no entrance to the cabin, cockpit or pilot station on which 6the word "Experimental" can be placed. Given the size ofthe UAS, two

-inch lettering will be impossible. The word "Experimental" will be placed on the fuselage in compliance with 45.29 (f). The equivalent level of safetywill be provided by having the UAS marked on its fuselage as required by 45.29 (f) where the pilot, observer and others working with the UAS will see the identification ofthe UAS as "Experimental." Miami Dade College shall mark its UAS on the belly ofits fuselage, placing the word "Experimental" and the "N" number as required by 14 C.F.R. 45.29 (f) so that the PIC (Pilot in Command) or and operator, oranyone assistingwith the UAV including spectators will observe the markings. The FAA has previously issued exemptions to this regulation through Exemptions Nos 8738, 10 1 67, 1 0 167 A and 10700. 

### (c)14 C.F.R. 61.113 

### (a) & 

### (b): Private Pilot Privileges and Limitations: Pilot in C

ommand. Pursuant to 14 CFR 61.113 (a) & (b), no person who holds a private pilot license certificate may act as a pilot in command ofan aircraft that is carrying passengers or property for compensation or hire. MDC may achieve an equivalent level ofsaf ety as achieved by current Regulations because the applicant's UAS do not carry any pilots or passengers nor property. The risks attendant to the operation ofUAS is far Jess than the risk levels inherent in the commercial activities outlined in 14 CFR 61. The PIC of the UAS will have as a minimum a Private Pilot's License alongwith a current Third Class or higher Medical Certificate meeting or exceeding the current safety levels in relation to 14 CFR 61.113 (a) & 

### (b). Further, a licensed private pilotwill ensure regulations and piloting skills are maintained based on the operation ofthe UAS. MDC Full time faculty (s) and Adjunct Faculty(s) assigned to teach these courses will be employing person(s) with a minimum ofa Private Pilot License to operate UAS, an exemption is also sought from 14 CFR 61.113, which restricts private pilot certif icate holders from flying aircraft for compensation or hire, and which would also require a second class medical certificate

. Mostifnot all MDC Full Time/ Adjunct instructors possesses Flight I nstructor Certificate with current Medical Certificate ofa third class or higher. 

### (d)14 C.F.R. 91 .7 (a): Civil AircraftAirworthiness Section 9 1.7 (a) prohibits and individual from operating a civil aircraft unless it is in an airworthy condition. As there is no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard may apply for determining airworthiness. Given the size, weight and operational capability ofthe D}l Phantom 2 UAS vehicle, which weighs less than 3 pounds and would be flown at 25 mph or less, an equivalent level ofsafety will be achieved by determining compliance with MDC in regards to UAS operation.
7

### (e)14 C.F.R. 91.9 (b); Civil aircraft flight manual, marking and placard requirements This regulation depicts in Section 91.9 (b) (2) requires that 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 ofthis 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. As there are no on board pilots or passengers, given the size ofthe UAS's, this regulation is inapplicable. An equivalent level ofsafetywill be achieved by maintaining all safety /flight manuals delineating areas ofwhere safety can be defined at the Pilot control station. The FAA has previously issued exemptions to this regulation in Exemption Nos 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167 A, 10602, 10700 and 32827. 14 C.F.R. 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor. 

### (f)14 C.F.R. 91.103 PreFlightAction This regulation provides that each pilot in command is require to take certain actions before flight to ensure the safety offlight. As FAA approved rotorcraft flight manuals will notbe provided for the aircraftan exemption will be needed. The PIC will take all actions as stated in the FOM (Flight Operating Manuals) in Section 4 under normal procedures including but not limited to reviewing weather, flight battery requirements, landing and takeoffdistances and aircraft performance data before initiation offlight. 

### (g) 14 C.F.R. 91.109 (a); 

### Dual controls for instruction This regulation section 91.103 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. UAS aircraft and orremotely piloted aircraft by their design do not possess fully functioning dual controls since they are unmanned and the control functioning levers are simplified for one operator ata time. The flight control system ofthe DJI Phantom 2 is accomplished through the use ofa control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number ofaircraft and for flight instruction in experimental aircraft. The DJI Phantom 2 would be classified as experimental aircraft meeting the requirements for FAA approved exemption. A lso, the equivalent level ofsafety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed ofthe aircraft.


### 8

### (h) 14 C.F.R. 91.119; Safe altitudes over obstacles Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Specifically, 91.119 (c) limits aircraft flying over areas other than congested areas to 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. As it relates to UAS aircraft, specifically the DJI Phantom will never be operated at higher than 200 feet AGL, with the exception that in certain circumstances where the UAS is used to survey or photograph a structure who height exceeds 200 feet AGL, the UAS will not be operated more than 100 feet above the highest point on the structure. For the safety ofall persons near or around the structure, the UAS will be operated under strict security measures where the structure and people will not be exposed to operations without their pre-obtained consent. As it relates to flight operations with aircraft or rotorcraft weighting far more than the maximum 55 Lbs, proposed herein and the lack offlammable fuel, any risk associated with these operations is far less than those presently presented with conventional aircraft operating at or below 500 AGL. In addition to the low altitude operations of the UAS will ensure separation between these UAS operations and the operations of conventional aircraft that must complywith Section 91.119. In addition, every flight will be conducted over land owned or controlled by Miami Dade College unless permission is granted by the public or private organization in accordance with Miami Dade College policy and its mutual agreements between the parties involved. 

### (i) 14 C.P.R. 91.121; Altimeter setting This petition requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the petition requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation ofthe departure airport or barometric pressure. As the UAS does not carry or possesses a barometric altimeter, but instead a GPS altitude read out, an exemption is required

. An equivalent ofsafety will be enhanced pursuant to 14 C

.F.R. 91.121 can be accomplished by (1) UAS operated at 200 AGL or below, (2) within visual line of sight by the PIC (Pilot in Command), (3) where the GPS based altitude would indicate real time altitude indication to the PIC (Pilot in Command) at a ground based on screen display and (4) before each flight, a zero altitude initiation point is established for the PIC to verify exact altitude based on the accuracy ofthe onboard GPS.

9

### U) 14 C.F.R. 91.151 (a); Fuel minimum This regulation prohibits an individual from beginning "a flight in an airplane under VFR conditions unless (consideringwind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and assuming normal cruising speed (1) During the day, to fly after that for at least 30 minutes; or (2) at night, to fly for at least 45 minutes." Based on the DJI Phantom 2 UAS ofmaximum LiPo (Lithium Polymer) batterypower ofmaximum 25 minutes, the technological limitations on the UAS battery means that no meaningful flight operations can be conducted while still maintaining a 30 minutes battery reserve. LiPo flight battery does have a battery level indicator, which indicates the percentage ofbattery power from 25% to 100%. An exemption from the fuel requirements of 14 C.F.R. 91.151 (a) is required

. (k) 14 C.F.R. 91.203 (a) & (b) Maintenance inspections This regulation states: (a) except as provided in 91

.715, no person may operate a civil aircraft unless it has 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) ofthis 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. As indicated in Exemption No. 11066, Regulatory Docket No. FAA 2014

-0353, the original intent ofthese regulations was to display an aircraft's airworthiness certificate and registration documents so they would be easily available to inspectors and passengers. Since the DJI Phantom 2 UAS are small in nature, does not carry passengers, an equivalent level ofsafety will be accomplished by following the FAA's Memorandum subject "Interpretation regardingwhether certain required documents may be kept at an unmanned aircraft's control station," dated August 8, 2014. It is ultimately decided that UAS documentation for flight will be stored at MDC Eig Watson School ofAviation location

. (I) 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417 (a): Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, exceptas provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed in Part 43 ofthis chapter." Section 91.407 similarly makes reference to requirements in Part 43. Section 91.409 (a) (2) requires an annual inspection for the issuance ofan airworthiness certificate

. 10Section 91.417 (a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records ofapproval ofthe aircraft for return to service.



### VI. DJI Phantom 2 UAS Vehicle Description: DJI Phantom 2 Vision and Drone Quadcopter has a gimbal stabilized 14 MP 1080p Camera from DJI and is based on the same air frame as the Phantom 2 and Phantom 2 Vision. DJI Phantom 2 Vision and Drone Quadcopterweighs less than 3 pounds, small and compact in size, and with speed limited to 23 mph and its vertical ascent limited to 5 to 10 mph. It features a 14 MP camera that is stabilized and controlled with an integrated 3-axis gimbal. Gimbal stabilization makes the Phantom 2 Vision+ ideal for shooting aerial footage and photos. The camera can take 14 MP, Adobe DNG RAW photos, and can record video in 1080p Full HD at 30 fps or 720p at 60 fps for creating slow motion effects. The Phantom 2 Vision has a radio control system often referred to as a transmitter. It features a 5,200 mAh battery that can sustain the quadcopter in the air for up to 25 minutes. The transmitter features a line-of-sight range ofup to 2625', depending on conditions. The camera is controlled via 2.4 GHz WI

-Fi using an application available for iOS and Android devices

. Using the supplied mount, the Phantom 2 can attach to a smartphone directly to the controller, giving the ability aside from the remote controller a "heads up" display directly from the camera's point

-of-view. From the app you will also be able to start and stop video recording, take a snapshot and tilt the camera up or down

.Also included in a 4GB MicroSD that can assist in conducting filming and photos. As with the other Phantom 2 models, the 5200 mAh battery system is simplified over the original version 1 Phantom. The battery slots in, and provides LED indicators on outside, tail

-end ofthe aircraft so they can be seen in flight. Charging is also simplified, with all ofthe charging circuitry built into the battery itself. The recharge ofthe battery can be conducted by simply plugging it into the wall with the supplied universal AC adapter. The Phantom 2 Vision+ includes a Wi-Fi Range extender that will increase the wireless range ofthe smartphone used for FPV camera operation up to nearly 2300' feet line-of-sight. The range extender mounts on the transmitter (radio controller) along with the smartphone.

11Features: Gimbal Stabilized 14 MP HD Camera Attitude and GPS Attitude Flight Modes Return to Home Failsafe Intelligent Orientation Control (IOC) DJI Vision iOS and Android App Assistant Software Slot-In Battery with LED Status Indicators Included 5.8 GHz Transmitter LED Status Indicator Self

-Tightening Rotor D

J

I Phantom 2 Specifications: General Features Ready to Fly, Multifunctional Quad-rotor System Customized H3-2D and H3

-3D Gimbal Support Precision Flight and Stable Hovering 25min FlightTime & Smart Battery Auto Return-to-Home & Landing Advanced Power Management Intelligent Orientation Control (IOC) Easy Battery Replacement Self-tightening Propeller Video Downlink Support CAN

-Bus Expansion Module Aircraft Weight (Battery & Propellers Included) 1000g HoverAccuracy (Ready To Fly) Vertical: 0.8m; Horizontal: 2.5m Max Yaw Angular Velocity 200° 

### js Max Tilt Angle 35° Max Ascent 

## I Descent Speed Ascent: 

### 6mjs; Descent: 2m/s Max Flight Speed: 15mjs (Not Recommended) Diagonal Length: 350mm FlightTime: 25mins Take

-OffWeight: $l300g Operating Temperature: -10°C**~** 50°C Supported Battery: DJI Smart Battery

12

### D}I Smart Battery Type: 3S LiPo Capacity: 5200mAh, 11.1 V Charging Environment Range: 00 to 400 Discharging Environment Range: -200 to SOD 2.4GHz Remote Control 

### Operating Frequency 2.4GHz ISM Communication Distance (Open Area): 1000m Receiver Sensitivity (1%PER): -97dBm Working Current/Voltage: 120 mA@3

.7V Built

-In LiPo BatteryWorking Current/Capacity: 3.7V, 2000mAh


### V. Airworthiness ofthe DJI Phantom 2 UAS Pursuantto 14 C.F.R Part 21, Subpart H, Airworthiness Certificates and 14 C.F.R. 91.203 (a) (1), the FAA has indicated that there is no need for an exemption needed for this Section, due to the fact that under the Reform Act that the UAS selected in the DJI Phantom 2 Vision and Drone Quadcopter, provides an adequate level ofsafety. Such safety features include, the size, the weight and the operational capability ofthe UAS vehicle. The UAS weighs less than 3 pounds and would be flown at 23 mph or less, while being flown outside ofcontrolled airspace. The UAS does not carry pilots or passengers and no materials and or flammable liquid, fuel, and explosive devices are to be carried by this device, as further outlined in the MDC operation specifications.

VI. 

### Training The School will mandate that all Instructors and Spotters, utilized in these educational programs, complete a mandatory 25 hour training program which will cover safety, UAS operations, regulatory issues, and emergency situations. Records will be appropriately maintained at the School concerning this training. Additionally, each instructor who will act as a pilot in command (PIC) will have a minimum ofa private pilot rating and each PIC and Spotter, will have completed the following MDC aviation courses ATT 1100 Private Pilot Theory, ASC 1550Aerodynamics, ASC 1610 Engines and Structures, and ASC 1210 Meteorology.

13VII. Safety The School will develop a safety manual to be issued to all instructors. The safety manual will establish all pre-flight and post-flight checklist requirements, as well 

### as, operational actions to be followed through the UAS operations

.

VIII. Operating Conditions: The DJI Phantom 2 Vision and Drone Quadcopter dimensions are 29 CM X20 CM, weighing 1000g. In still air conditions, the maximum air speed is 10 mph to 23 MPH. The DJI Phantom has 4 motors powered by a 11.1 V, 5200 mAh3 SI Li-Po battery. Listed below are the MDC operating standards and limitations as proposed for this educational program utilizing the DJI Phantom 2 Vision and Drone Quadcopter: 1. The UAS will weigh less than 3 pounds, including the fully mounted camera. UAS will have a maximum operating speed ofapproximately 23 mph

. 2

. UAS flights will be operated within the line ofsight ofthe Pilot in Command (PIC) and the visual observer (Spotter) who will maintain horizontal and vertical observation at all times. 3. A ll UAS operations will occur between the hours of9 AM and 3 PM. 4. The maximum flight time for each operational flight will be limited to 20 minutes from its 25 minutes ofits maximum battery power. A reserve of5 minutes will ensure the ability to safely terminate the flight without undue incident or hazard to persons and or property
. 5. UAS flights will be operated at an altitude ofno more than 200 feet above ground level (AGL) and no more than 100 feet above an elevated platform. 6
. UAS flights will operate at a lateral distance ofno less than 100 feet from persons or property in order to avoid any interference with third parties during training or demonstration exercises

. 7

. UAS flights will be conducted at a maximum lateral distance of500 feet from any inhabited structure, vehicles or vessels

. 8

. A minimum crew will consist ofa UAS pilot (PIC)(holding a minimum ofa Private Pilot License along with a Third or higher C lass Medical Certificate) and a Spotter. The PICwill be required to act and perform as a visual observer and 148. A minimum crew will consist ofa UAS pilot (PIC)(holding a minimum ofa Private Pilot License along with a Third or higher Class Medical Certificate) and a Spotter. The PIC will be required to act and perform as a visual observer and maintain horizontal and vertical distance at all times when operating the UAS and its additional components to include cameras and or video equipment. The crew will also include a Spotterwho will assist the PIC in the UAS operations. All Spotters will have completed a minimal educational requirement of ATT 1100 Private Pilot Theory, ASC 1550 Aerodynamics, ASC 1610 Engines and Structures, and ASC 1210 Meteorology. 9. All members ofthe flight crews for each operation will have been certified as educational trainers under the MDC certification program. 10. A pre-flight briefing and post-flight briefing will be conducted after each UAS flight in order to evaluate all necessary information to maintain the highest safety offlight operation and that day's operations. 11. The PIC (Pilot in Command) will obtain and document all persons involved with the planned operation and will maintain a ledger ofall information for the particular type flight, which includes any and all vertical and horizontal distance from any persons and or property. 12. Each UAS flight, regardless ofwhether it is conducted for training, testing, or evaluating the operational capability ofthe UAS, which includes maintenance, will be logged in by the PIC (Pilot in Command) or Spotter in an approve MDC UAS logbook. The flight will include the name ofits PIC (Pilot in Command) and Spotter, pilot license information, date, duration ofthe flight, location, and the type ofUAS flight, to include MDC training curriculum, testing and or maintenance, ifrequired. 13. The PIC and Spotter shall maintain communication with the VAS, at all times, either by voice, radio, remote control, or through the use ofa smart phone or text. 14. Ifthe UAS loses communication with the PIC or Spotter, or loses GPS signal, the UAS shall have the capability to return the UAS to a pre-determined location away from any airport by a distance not to be less than 5 miles

. 15. All UAS flights will be conducted during the day and under visual flight rules and meteorological conditions. 16. All UAS flights will be conducted at a distance exceeding 5 nautical miles away from any airport including towered or non-towered airports, to avoid any type ofconfrontation with arriving or departing aircrafts.
1517. All flight operations will be conducted away from any congested or populated areas. 18. The UAS will be operated and maintained in accordance with the requirements ofthe Manufacturer's Manuals and any manufacturer Safety Bulletins. 19. Prior to the commencement ofoperations, all required operational permissions and permits will be obtained from state, county or city jurisdictions, including local law enforcement, fire or other appropriate governmental agencies to include the FAA
20. A contingency plan will be in effect to safely terminate the UAS flight ifthere is a loss ofcommunication between the PIC (Pilot in Command) or Spotter and the UAS. Also, a contingency plan will be put into effect to abort the flight in case ofan unpredicted obstacle entering the operating airspace ofthe UAS or if an emergency occurs during the UAS flight. 21. UAS flight operations will be conducted by the PIC (Pilot in Command) and Spotter, using the DJI Phantom 2 remote control system. The radio frequency spectrum used for the operation and control ofthe UAS shall be in compliance with Federal Communication Commission (FCC) or other acceptable governmental agency requirements

. 22. The DJI Phantom 2 has released an upgraded remote control (Models NPVt581, NDJ6 and NRC 900) to replace the previous models (PVTS81, DJ6 ad RC900). This upgraded remote control system comes with new features, including gimbal control dial, built in LiPo (Lithium Polymer) battery, and battery level LED indicators. This new remote control system is compatible with the Phantom 2 Vision, Phantom 2 Vision and Phantom 2 to operate the DJI Phantom 2. This upgraded remote control system will be inspected before any UAS flight for damages to the equipment, the control throttles, its locking mechanism, its dial buttons, and its battery level indicator lights. 23. The LiPo (Lithium Polymer) batteries must be charged with a LiPo (Lithium Polymer) battery charger. The PIC (Pilot in Command) and Spotter will ensure that the batteries are fully charged and they are never overcharged before each flight. Both members ofthe crew will ensure that the battery is fully charged they are disconnected from the charger. Batteries will never be allowed to be charged below 3V per cell, while only using lithium polymer (LiPo) (Lithium Polymer) batteries. 24. The PIC (Pilot in Command) and Spotterwill ensure that when the DJI Phantom 2 is stored for an extended amount oftime ofmore than a week, the batteries shall be removed from its remote control system and stored in a fireproof container for proper storage. 1625. Transportation Security Administration (TSA) security and background checks will be completed for all MDC program participants (PIC, Spotters)

. 

### XI. Pre-flight checklist Pre-flight checks will be performed by the PIC prior to each flight and at predefined intervals as part ofthe maintenance schedule. 1. Visual inspections ofthe airframe; 2

. Visual inspections ofthe remote control system; 3. Visual inspections ofthe four propellers, including attachment; 4. Verify LiPo battery for level indicator; 5. Verify GPS and Gimbal acquisition; 6. Calibrate compass (rapidly switching fully upjdown)(verify LED lights); 7. Verify remote controller for batteryvoltage and throttle check; 8. Assembly ofVideo/Camera and verify for proper mounting on the airframe; 9. Plan and up load mission 10. Visual overall inspection before startup and first flight



### XII. Post flight checklist

The Post-flight checks will be performed by the PIC after each flight and at predefined intervals as part ofthe maintenance schedule. 1. Verify shut down procedure ofboth airframe and remote control system; 2

. Visual inspection ofairframe for damages; 3

. Disassembly ofLiPo and remote control batteries for proper storage; 4. Disassembly ofthe four propellers (inspection for chips, cracks, etc); 5. Disassembly ofvideojcamera component; 6. Proper storage ofall components in the DJI Phantom 2 enclosed suitcase. 7. Logging ofhours offlight/maintenance discrepancies;


### XIII. Public Interest The public interestwill be satisfied by granting the MDC and the School this petition for exemption

. Congress has established a national policy that promotes the early integration ofUAS into the National Airspace System (NAS) in a controlled and safe working environment. This petition offered by MDC and the School promotes the highest level ofsafety by exceeding promulgated minimum safety standards. As an institution for higher education, MDC understands the level ofcollaborative effort in working with the FAA by proposing this petition in the public interest ofthe South Florida area. MDC feels we have an obligation to improve public safety by creating an educational program designed to teach the fundamentals ofUAS flight operations. 

### 17The proposed UAS operations in this petition for exemption will benefit students, federat state, and local governments and the aviation industry in the South Florida area by allowing MDC to initiate formalize educational trainingwith UAS systems. XIV. Privacy The MDC and the School will only conduct UAS flight operation over property it owns; or which it has received the consent ofthe owner or the organization in a mutual agreement between the parties. MDC will also not record and capture anyvideos, photographs, or images ofany third party individuals or their property, unless prior permission has been granted to MDC.

Approved and submitted by: 

# (i(b.;)hfi

Director Eig-Watson School ofAviation Miami Dade College 2460 N

.W

. 66 Ave. Bldg. 701 Suite 204 Miami, FL 33122 

### Ph. (305) 237

-5080 Fax

. (305) 237

-5956 www.mdc

.edu/aviation e-mail: tjargiel@mdc.edu

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