1 May 2 0 th , 2015

Michael Moore Mailstop 50, Biology Department

Woods H ole Oceanographic Institution Woods Hole, MA 02543

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

**RE: Petition for Exemption and Relief from Specific Regulations of Title 14** 

**of the Code of Federal Regulations Pursuant to Section 333 of the FAA** 

**Modernization and Reform Act of**  **2 012 (Public Law 112** 

**- 95) Regarding** 

**Commercial Employment of Unmanned Aircraft Sy**  **stems (UAS)**

Dear Sir/Madam,

Pursuant to Section 333 of Public Law 112

- 95 commonly known as the “ Woods Hole Oceanographic institution hereby applies for authorization to conduct commercial unmanned aerial systems (UAS) operations within the United States National Airspace System (NAS) for the purpose of Research, Education and UAS platform development.

**Federal Register Summary**

Pursuant to 14 CFR §11.81, the following summary is provided for publication in the Federal Register, should it be determined t hat publication is needed:

**Woods Hole Oceanographic Institution seeks exemption from 14 CFR Part 21,**  **Subpart H; 14 CFR Part 27; 14 CFR 45.23(b); 14 CFR 61.113(a)(b); 14 CFR 91.7(a); 14 CFR 91.9(b)(2)(c); 14 CFR 91.103; 14 CFR 91.109(a); 14 CFR 91.119; 14**  **CFR 91.121; 14 CFR 91.151(a); 14 CFR 91.203(a)(b); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); CFR**  **91.409(a)(1) and (a)(2); 14 CFR 91.417(a)(b) to allow commercial employment of Unmanned Aerial Systems (UAS) in support of research, education and UAS platform** 

**de velopment in the areas of oceanography, limnology, and environmental science.**  **This exemption will enhance safety by reducing risk to the general public and property owners from the substantial hazards associated with performing equivalent** 

**work with conv entional aircraft and rotorcraft.** 2 The name and address of the applicant is:

Dr. Michael J Moore Mailstop 50 Biology Department Woods Hole Oceanographic Institution Woods Hole, MA 02543
mmoore@whoi.edu

508 289 32283 **GLOSSARY OF ABBREVIATIONS**

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Control

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airmen

PIC Pilot in Command

Section 333 FAA Modernization and R eform Act of 2012, Section 333

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VO Visual Observer4 **INTRODUCTION AND INTEREST OF THE PETITIONER** 

The use of small unmanned aerial systems (sUAS) in terrestrial commercial and science applications is now widespread and transforming agricultural assessments, environmental compliance regimes and spatial ecological science . These devices are used regularly to reduce costs , increase safety and boost knowledge of key agricultural parameters, to assess progress and environmental compliance in mining operations and occasionally to study the terrestrial habitats and aggregations of wildlife [3] . The use of sUAS in ocean science appli cations is also growing, and the availability of safe and sophisticated commercial hardware and software solutions is now facilitating their use by marine researchers. The use of sUAS by marine researchers can provide significant benefits including reduced costs, greater survey efficiency, reduced wildlife disturbance, reduced risk to human pilots and observers and higher data quality and quantity , yet there are few programs exploring these opportunities. The Woods Hole Oceanographic Institution is developi ng a UAS program to 1) help meet the growing educational needs of marine scientists seeking to use sUAS in ocean and coastal applications and; 2) to support sUAS

- based research in coastal and marine environments nationally and internationally . To achieve t hese goals, our research program must engage in

domestic sUAS operations for research, education and training purposes. Due to the nature of our work, these flights will occur predominantly in remote coastal areas, away from human activities and often excl usively over water. UAS are developing as a legitimate and robust means of conducting research that heretofore have been possible only from manned aircraft. Such t raditional survey techniques are expensive

, incur substantial risk to personnel and produce lower quality data

. Our work addresses these issues through marine science UAS applications to the benefit of society at large.

**OVERVIEW CHARACTERISTICS OF PROPOSED UAS**

**APH**

**- 22**  **Mariner DJI Phantom**  **Aircraft Type** Multirotor (6) Multirotor ( 4 ) Multirotor ( 4 ) **Aircraft Weight** 1.8kg/4 lbs 1. 7 kg/3. 8 1bs 1. 0 kg/ 2.2 1bs

**Max Take off Weight**  1.8kg/4 lbs 2.0 kg/4.4 lbs 1. 0 kg/ 2.2 1bs

**Dimensions** 812 x 812 mm 560 x 560 mm 360 x 360 mm **Max Flight time**
(aprox) 30 min 2 2 min 2 5 min

**Max airspeed** 30 kts 3 0kts 3 0kts

**Propulsion** Brushless DC motor Brushless DC

motor Brushless DC

motor

**Power** 14.8 v 4 Cell Lithium Polymer battery 14.8 v 4 Cell Lithium Polymer battery 11.1 v 3 Cell Lithium Polymer battery5 **Payload** Digital compact

camera Digital compact / V ideo camera Digital compact / V ideo camera

**Airframe material** Aluminum Injection molded plastic Injection molded plastic

**QUALIFICATION FOR APPROVAL UNDER SECTION 333 OF THE REFORM ACT**

The proposed operations in this petition for exemption qualify for expedited approval under Section 333 of the Reform Act. Each of the statutory criteria and other potentially relevant factors are satisfied.

The proposed operations would permit the use o f small and relatively inexpensive UAS under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) away from populated areas; (4) would provide an increased level of safety beyond that existing when fixed or rotor wing aircraft are used to accomplish the

same purpose.

The UAS's planned to be operated are rotorcraft, each weighing typically less than 15 lbs., and always less than 55 lbs., including payload. They would operate, under normal conditions, at a speed of no more than 3 0 k nots. The principal construction material of the UAS aircraft would typically be foam, c arbon fiber, aluminium and/or plastic. Operations will be performed by a qualified UAS Pilot in Command (PIC), as outlined below, to insure that the UAS will "not creat e a hazard to users of the national airspace system or the public." Given the small size of the UAS involved and the pre

- planned environment within which they will operate, the applicant believes that these operations fall squarely within that zone of safe ty (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UAS to commence immediately. Also, due to the size of the UAS and the pre

- defined, restricted area in which the UAS will operat e approval of the application presents no national security issue. The operation of UAS by knowledgeable professionals will serve to enhance safety, add to the public benefit, and reduce environmental impacts related to current methods of manned

aircraft f light operations. These limitations and conditions to which the operator, or its employees, acting as UAS PIC agrees to be bound when conducting commercial operations under a FAA issued exemption:

1. Operations authorized by this grant of exemption are limited to the following

aircraft: **APH**

**- 22, Mariner**  and **DJI Phantom**

2. UA (aircraft and payload) will weigh less than 55lbs.

3. UA will be operated at altitudes not greater than 2 00 feet AGL. Altitudes

reporte d to ATC will be in feet AGL.

4. UA will be flown at ground speeds not greater than 30 knots.6 5. The UA S PIC will hold either an airline transport, commercial, private, recreational or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S driver’s license issued by a state, the District of Columbia, Puerto Rico, a ter ritory, a possession, or the Federal

government. The PIC must also meet the recent flight experience requirement stated in 14 CFR § 61.57 and flight review requirements stated in 14 CFR § 61.56.

6. In addition to holding an FAA issued airman certificate, U AS PIC must complete a Woods hole Oceanographic Institution UAS Training Program. This training will include detailed review of manufacturer operating manuals

and practical demonstration of ability to safely operate UAS in a manner

consistent with how the UAS will be operated under this exemption (to include evasive and emergency maneuvers and maintaining appropriate distances from persons, vehicles, vessels and structures). PIC qualification will have a currency requirement of at least three take

- offs an d landings within the preceding 90 days. PIC qualification flight hours will be logged in a manner consistent with 14 CFR § 61.51.

7. UA will not be operated within 5 nautical miles (NM) of an airport having an operational control tower, or 3 NM of an airp ort with a published instrument flight procedure but not an operational control tower, or 2 NM of an airport without a published instrument flight procedure or operational control tower, or 2 NM of a heliport with a published instrument flight procedure.

F lights will be operated in Class G airspace whenever possible. If operation in other airspace is required, the relevant controlling agency will be notified at least 24 hours prior to the operation and, if required, any necessary permission obtained

8. UAS fli ghts will operate within visibility and cloud clearance requirements equivalent to Visual Flight Rules (VFR).

9. UAS operations will not be conducted during night, as defined within 14 CFR § 1.1.

10. UA flights over land will not be operated by the PIC from any m oving vehicle or device. UA flights conducted entirely over water may be operated from a

suitable vessel.

11. UA will not be operated from a raised platform.

12. The UA will remain clear of and yield right of way to manned aviation operations.

13. UA will be operated within visual line of sight (VLOS) of the PIC at all times. The PIC will use human vision unaided by device other than corrective lenses as specified on PIC’s FAA medical certificate or drivers license

. 14. UAS operations will employ a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC maintains VLOS capability. The VO and PIC must be able to communicate verbally for the duration of the7 flight. Electronic messaging or texting is not allowed during flight operations.

15. The VO will perform no duties other than assisting the PIC see and avoid other aircraft, obstacles, persons or property.

16. UAS will be equipped with an autopilot system which will be at least equivalent to a MikroKopter system. The UAS will utilize GPS nav igation, failsafe’s, return

- to

- home (RTH) and flight abort safety features.

17. Prior to each flight the PIC will inspect the UAS to ensure it is in a condition for safe flight. Checklists developed from manufacturer operating documents

will be the basis for this inspection. If the inspection reveals a condition that affects safe operation of the UAS, the aircraft is prohibited from operating until necessary maintenance has been performed and the UAS is found to be in a safe condition for flight. The Ground Control Station must be included in the preflight inspection.

18. All UAS operations will be conducted over remote and sparsely populated property or over open waters. Permission for flight will be obtained in advance from property owners or controlling agenc y. A Ground Station will be connected, by radio communication, to the UAS during the entire flight, which will give the PIC flight information such as GPS Position, Altitude, Air speed, Battery Remaining, and other telemetry information.

19. Flight boundaries will be established for each flight and such boundaries will be designed such that the UA will pass no closer than 500 feet from nonparticipating persons, vehicles or structures.

20. If the UAS loses communications or loses GPS signal, the UA will return to a predetermined location within the established flight boundary and land or be recovered in accordance with manufacturer operations documents.

21. The PIC will abort any flight in the event of unpredicted obstacles,

occurrence of adverse weather or loss of UAS f light control capability in accordance with manufacturer operations documents.

22. The PIC is prohibited from beginning a flight unless (considering wind and forecast conditions) there is enough power to fly the planned route to the intended landing point and land the UAS with 25% of battery capacity remaining.

23. Documents required by 14 CFR § 91.9 and 91.203 will be available to the PIC at the Ground Control Station of the UAS whenever the aircraft is operating.

These documents will be made available to the Adm inistrator or any law enforcement official upon request.

24. Before conducting flight operations, the radio frequency spectrum used for operation and control of the UA must comply with Federal Communications Commission (FCC) or other appropriate government ove rsight agency requirements.8 25. A Flight Operations and Maintenance Log will be maintained for each UAS. Cumulative flight hours, maintenance activities, repairs, alterations and inspections will be noted.

26. Any UAS maintenance or alterations that affect UAS op eration or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the Flight Operations and Maintenance Log.

**SPECIFIC SECTIONS OF 14 CFR FROM WHICH PETITIONER SEEKS EXEMPTION** 

**OR RELEIF**

**14 CFR Part 21, Subpart H**

**– Airworthiness Certificates and 14 CFR §**  **91.203(a)(1)**

The FAA has stated that no exemption is needed from this section if a finding is

made under Part 11 and Section 33 3 of the Reform Act that the UAS selected provides an equivalent level of safety when compared to civil aircraft normally used for the same application. The petitioner submits that given the small size of the UAS, the limited operating areas and procedure s defined within the training and operations section of the petition, an equivalent level of safety is obtained and exemption is not required (see Grant of Exemption to Astraeus Aerial, Docket No.

FAA

- 2014

- 0352). If however, the FAA determines that there are some characteristics of the chosen UAS that fail to meet the requirements of the Reform Act, an exemption is requested.

**14 CFR Part 27**

**– Airworthiness Standards: Normal Category Rotorcraft** 

14 CFR Part 27 sets forth the procedural requirements for air worthiness certification of normal category rotorcraft. To the extent petitioner’s UAS would otherwise require certification under Part 27, petitioner seeks exemption for the same reasons identified in the request for exemption from 14 CFR Part 21, Subpar t

H.

**14 CFR § 45.23 (a)(b) and 91.9 (c)**

**– Marking of the Aircraft** 

Regulation 45.23 provides: ( a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration) followed by the registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. (b) When 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 each9 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. Regulatio n 91.9 (c) provides: No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter.

The UAS has no entrance to the cabin, cockpit or pilot station on which markings can be placed. Gi ven the small size of the UAS, two

- inch lettering will not be possible. In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that the aircraft “have identification (N

Number) markings in accord ance with 14 CFR Part 45, Subpart C if the markings are as large as practicable.” The petitioner additionally proposes to place all required markings, placards, flight envelope restrictions, cautionary notices in an easily

visible location at the UAS Grou nd Control Station. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 8738, 10167, 10167A and

10700.

**14 CFR § 91.9(b)(2)**

**– Aircraft Flight Manual in the Aircraft** 

Regulation 91.9 stipulates (b) No person may operate a U.S.

- reg istered 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, a nd placards, or any combination thereof.

Given the size of the UAS, they have no place or ability to carry a flight manual aboard the aircraft. An equivalent level of safety will be achieved by keeping the flight manual at the Ground Control Station wher e the pilot operating the UAS will have immediate access to it. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 10167, 10602, 32827 and 10700.

**14 CFR § 61.113 (a)(b) and 61.133(a)(i)(ii)**

**– Private and Commercial Pilot**  **Privilege and Limitations**

Regulation 61.113 stipulates (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with an y business or employment if: (1) The flight is only10 incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

Regulation 61.133 stipulates (a) Privileges

— (1) General. A person who holds a commercial pilot certificate may act as pilot in command of an aircraft

— (i) Carrying persons or property for compensation or hire, provided the person is qualified in accordance with this part and with the applicable parts of this chapter that apply to the operation; and (ii) For compensation or hire, provided the person is qualified in accordance with this part and with the applicable parts of this chapter that apply to the operation.

Unlike a conventional aircraft that carry pilot, passengers and car go, the proposed UAS are remotely controlled and carry no persons or cargo. The UAS are capable of a high degree of flight automation and employ technical capabilities that limit the potential for operation in an unintended manner. It is the petitioner’s belief that given the size, weight, speed, operating environment and operating capabilities of the UAS, an equivalent level of safety may be obtained by stipulating the UAS PIC must hold either an airline transport, commercial, private, recreational, or s port pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 11284, 11281, 11282 and 11296.

**14 CFR § 91. 7(a)** 

**– Civil Aircraft Airworthiness** 

Regulation 91.7 stipulates (a) No person may operate a civil aircraft unless it is in an airworthy condition.

Should this exemption be granted allowing commercial operation of UAS without an
airworthiness certificate, no FAA regulatory standard will exist for airworthiness of the UAS. An equivalent level of safety will be obtained by ensuring compliance with UAS operator and maintenance manuals and safety checklists prior to each flight.

**14 CFR § 91.121**

**– Altimeter Se**  **ttings**

Regulation 91.121 requires that (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,000 feet MSL, to

— (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph11 (a)(1)(i) of this section, the current reported altimeter setting o f an appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure.

Conventional aircraft are provided altitude data by a barometric altimeter that is most commonly set to a local barometric pressure and therefore reports altitude relative to MSL (Mean Sea Level). UAS operations are restricted to altitudes no greater than 2 00 feet AGL (Above Ground Level). For those UAS wi th a barometric sensor, greater utility and an equivalent level of safety will be obtained by setting the altimeter to read “zero altitude” when the UAS is on the ground prior to takeoff thus providing an AGL altitude readout. If no barometric sensor is a board the UAS, a GPS derived altitude similarly set to zero at the takeoff point will provide an equivalent level of safety. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 11066, 11065, 11062 and 11063.

**14 CFR § 91.151**

**– Fu**  **el Requirements for Flight in VFR Conditions**

Regulation 91.151 stipulates that (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and 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; or (2) At night, to fly after that for at least 45 minutes. (b) No person may begin a flight in a rotorcraft under VFR conditions unless (c onsidering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

This regulation is written based on the capabilities of tra ditional civil aircraft which typically have flight times with full fuel of several hours. For the majority of UAS which have flight times of an hour, or much less, this regulation would effectively deny an ability for the UAS to operate. The petitioner submits that an equivalent level of safety will be obtained by requiring that no UAS flight will begin unless (considering wind and forecast conditions) there is enough fuel (battery) to fly the planned route to the first point of intended landing and land with 25% of battery capacity in reserve

. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 2689F, 5745, 10673 and 10808.

**14 CFR § 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b)**

**– Maintenance Inspections** 12 Regulation 91.405 (a) requires that an aircraft operator or owner “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...” Regulation 91.407 (a)(1) similarly makes reference to requirements in Part 43

. Regulation 91.409( a)(2) requires an annual inspection for the issuance of an airworthiness certificate. Regulation 91.417( a) and (b) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certifica ted mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service.

Exemption from these regulations is needed because Part 43 and these sections apply only to aircraft with an airworthiness certificate. An equ ivalent level of safety will be obtained by requirement that each UAS will have a flight and maintenance log. Maintenance and inspections will be accomplished in accordance with manufacturer recommendations. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 11066, 11062, 11067A and 11065.

**14 CFR § 91.103**

**– Preflight Action** 

Regulation 91.103 stipulates Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

— (a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of whi ch the pilot in command has been advised by ATC; (b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information: (1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual

c ontaining takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircr aft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

The petitioner seeks exemption to the extent that an FAA

- approved Flight Manual is required. An equivalent level of safety will be provided by following the Operations Manual provided by the manufacturer. Additionally, the PIC will conduct preflight actions, to include performing all required checklists, reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas, before initiation of flight.

**14 CFR § 91.109**

**– Flight Instruction** 13 Regulation 91.109 stipulates, in part, that (a) No person may operate a civil aircraft (except a ma nned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

UAS by their design do not have fully functional dual controls. Flight control is accomplished through the use of a control interface t hat communicates with the aircraft via radio. Given the size, speed and limited operational parameters of the UAS, an equivalent level of safe training can be performed without dual controls. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 11066, 11062, 11067A and 11065.

**14 CFR § 91.119**

**– Minimum Safe Altitudes** 

Regulation 91.119 stipulates, in part, that, Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywh ere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. (b) Over congested

areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, a n altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (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.

An exemption to 91.119(c) is required because UAS operations will be conducted at altitudes no greater than 2 00 feet above the surface. The size, speed, weight and limited operational parameters of the UAS allow for an equivalent level of safety.

**WHY GRANTING THIS PETITION IS IN THE PUBLIC INTEREST**

As introduced above, the requested exemption would authorize the Applicant to perform commercial operations with sUAS that will provide significant benefits to the public interest:

1. The commercial use of sUAS to perform marine research and educational

activities at Woods Hole Oceanographic Institution in support of government entities, private research institutions, scientific studies and wildlife monitoring, all of which are critical to the well

- being of the general public.

This include s rapid studies of coastal geomorphology crucial to storm assessments and sea level rise, water quality studies, wildlife population assessments and critical habitat mapping.

2. A significant reduction in costs to conduct research, training and education

prog rammes. At present, our marine research programs that use aerial14 surveys can cost tens of thousands of dollars per day. By incorporating sUAS into these programs we can incur significant savings and more efficiently conduct research in the public interest

3. The use of sUAS will decrease congestion in the National Airspace System along with reducing the noise and air pollution generated during traditional manned aircraft flight operations.

4. When using UAS to complement field personnel, they reduce safety concer ns when gathering data from inaccessible or unstable/unsafe areas and in

extreme weather or terrain.

5. Operation of sUAS will substantially reduce the risk to life and property in the air, and on the ground, which is commonly associated with traditional

mann ed aircraft flight operations for marine science missions

. 6. Similar to the current manned aircraft flight operations in marine science that have been conducted for many decades, sUAS used for similar tasks will not generate any new privacy issues.

Approva l of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator's) responsibilities under Section 333(c) of the Reform Act to "establish requirements for the safe operation of such aircraft systems in t he national airspace system." Approval of this exemption will allow for safer, more efficient and less costly marine science missions, and produce much higher data quality.

**SUMMARY OF REGULATIONS FROM WHICH PETITIONER SEEKS EXEMPTION**

**OR RELIEF**

**14 CFR Pa rt 21, Subpart H** 

**14 CFR Part 27**

**14 CFR 45.23(b)**  **14 CFR 61.113(a)(b) 14 CFR 91.7(a)**  **14 CFR 91.9(b)(2)(c)**

**14 CFR 91.103 14 CFR 91.109(a)** 

**14 CFR 91.119**

**14 CFR 91.121 14 CFR 91.151(a)**  **14 CFR 91.203(a)(b) 14 CFR 91.405(a)**  **14 CFR 91.407(a)(1)**

**CFR 91.409(a)(1)**  **and (a)(2) 14 CFR 91.417(a)(b)** 15 **SUPPORTING AND TECHNICAL DOCUMENTS**

To be delivered under separate attachment

WHOI APH

- 22 operating manual WHOI Mariner operating manual WHOI Phantom operating manual