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May 18, 2015

U.S. Department of Transportation Docket Operations, M-30 1200 New Jersey Avenue, SE Room W12-140, West Building Ground Floor Washington, DC 20590-0001

Re: Petition of Ventura County Office of Ed ucation for an Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 to Operate Unmanned Aircraft Systems to Conduct Education and Training

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Moderniz ation and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Ventura County Of fice of Education (“VC OE”) hereby applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation of the 3D R obotics Iris (“Iris”) , and the 3D Robotics Aero-M (“Aero”) unmanned aircraft systems to conduct aerial education and training.

VCOE requests that the FAA revi ew this petition pursuant to its “summary grant” process as the FAA has already granted exemptions similar in all material respects to this petition to use the Iris and the Aero. See FAA Grant of Exception Nos. 11062, 11109, 11112, and 11213. The FAA has specifically granted exemptions to operate UAS to conduct education and training. See FAA Grant of Exception Nos. 11552 and 11493.

I. REGULATIONS FOR WHICH EXEMPTION IS REQUESTED

VCOE requests exemption from the following regulations:

 14 C.F.R Part 21, Subpart H;

 14 C.F.R Part 27;

 14 C.F.R § 45.23(b);

 14 C.F.R. § 45.27(a);

 14 C.F.R § 61.113;

 14 C.F.R § 91.7(a);

 14 C.F.R § 91.9(b)(2);

 14 C.F.R § 91.9(c);

 14 C.F.R § 91.103;

 14 C.F.R § 91.109(a);

 14 C.F.R § 91.119;U.S. Department of Transportation Page Two

2  14 C.F.R § 91.121;

 14 C.F.R § 91.151(a) & (b)

 14 C.F.R § 91.203 (a) & (b);

 14 C.F.R § 91.405(a);

 14 C.F.R § 91.407(a)(l);

 14 C.F.R § 91.409(a)(2);

 14 C.F.R § 91.417 (a) & (b).

This petition incorporates the material contained in the Iris Operation Manual, and the AeroM Operation Manual (togeth er, the “Manuals”).

II. STATUTORY AUTHORITY FOR REQUESTED EXEMPTIONS

This petition for exemption is submitted in a ccordance with Section 333 of the Reform Act. Congress has directed the FAA “to safely acce lerate the integration of civil unmanned aircraft systems into the national airspace syst em.” Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit opera tion of an unmanned aircraft system (“UAS”) where it does not create a hazard to users of the national airspace sy stem (“NAS”) or the public or pose a threat to national security based on the following considerations:

 The size, weight, speed a nd operational capability;

 Operation in proximity to air ports and populated areas; and

 Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant exemptions from the agency’s safety regulations and minimum standards when the Administrator decides a requested ex emption is in the public interest. See 49 U.S.C. §§ 106(f), 44701-44716, et seq . A party requesting an exempti on must explain the reasons why the exemption: (1) would benefit the public as a whole, and (2) would not adversely affect safety or how it would provide a level of safety at least equal to the existing rules. 14 C.F.R. § 11.81.

III. DESCRIPTION OF VCOE AND ITS SERVICES

VCOE has developed a curriculum to appl y UAS science, technology, and real world application for high school and middle school students. The curriculum is grounded in applied learning and applicati on ensuring relevant and robust experience in the technical skills for the manufacture, design, and operation of UAS in order to prepare students for careers in the manned and unmanned aerospace field. The necessity of the course was identified based on findings from the Vent ura County Workforce Improvement Board and the curriculum was developed under the r ecommendation of an Advisory Committee consisting of Public, Private, Military, Ae rospace and academic stakeholders. VCOE isU.S. Department of Transportation Page Three

3 headquartered in Camarillo, California and is committed to providing students with skills necessary for successful employment and to providing business and industry immediate access to a productive pool of skilled employees.
Alan Jaege r Ventura County Office of Education 5189 Verdugo Way Camarillo, CA 93102 Tel. (805) 383-1902 AJaeger@VCOE.org C/O William D. Janicki William V. O’Connor Morrison & Foerster LLP 12531 High Bluff Drive San Diego, CA 92130 Tel (858) 720-5100 WJanicki@mofo.com WOConnor@mofo.com

IV. DESCRIPTION OF PROPOSED OPERATIONS

VCOE is requesting exemptions from appli cable Federal Aviation Regulations (FARs) pursuant to Section 333 of the Reform Act to conduct aeronautical and UAS education and training for high school and middl e school students. VCOE has developed a curriculum to apply UAS science, technology, and real world application for these students. The curriculum is grounded in applied learning a nd application ensuring relevant and robust experience in the technical skills for the manu facture, design, and opera tion of UAS in order to prepare students for careers in the ma nned and unmanned aerospace field. VCOE proposes to operate small UAS under 400 feet and within line of sight in VFR conditions in order to demonstrate basic aerodynamic prin ciples, UAS technology, augment written and classroom study with in the field training, trai n and educate students on the various use-case applications of UAS, provide for a hands-on educational experience including routine and preventative maintenance, educat e students in the effective and legal integration of UAS into the National Airspace, demonstrate student id entified UAS capabilities and limitations.Use of a UAS will reduce safety risks because the UAS will not carry flammable fuel or a pilot.

The UAS operations in this peti tion are similar in all material respects to relief previously granted by the FAA in Grant of Exception Nos. 11062, 11109, 11112, 11213, 11552 and 11493. The reasons stated by the FAA in granting the exemptions listed above also apply to this petition, and the grant of this petition is in the public interest.

A. Aircraft to be Operated

1. The 3D Robotics Iris

VCOE will operate the Iris to conduct educ ation and training. The FAA has already approved the Iris for commercial use in F AA Exemption No. 11419 (FAA Docket No. FAA2015-0185) and FAA Exemption No. 11273 (FAA Do cket No. 2014-0913). The Iris is a battery powered quadcopter UAS with a maxi mum weight of less than five pounds and a flight time of up to 22 minutes. Th e Iris is shown in Figure 1 below.U.S. Department of Transportation Page Four

4 Figure 1– 3D Robotics Iris

The Iris is more fully described in the 3D Robotics Iris Operations Manual.

2. 3D Robotics Aero-M

VCOE will also operate the Aero to conduct ed ucation and training. The FAA has already approved the Aero for commercial use in FAA Exemption No. 11379 (FAA Docket No. FAA-2015-0059). The Aero is a battery powered quadcopter with a maximum weight of less than 3 pounds. The Aero is shown in Figure 2 below.

Figure 2– 3D Robotics Aero-M

The Aero is more fully described in the 3D Robotics Aero User Manual.U.S. Department of Transportation Page Five

5 B. VCOE’s Proposed Operations Demonstrate an Equivalent Level of Safety

1. General Description of Proposed Flight Operations

VCOE proposes to operate within the limitations and performance specifications listed in the application and in the Iris and Aero Manuals . These limitations provi de for at least an equivalent, or higher, level of safety for operations under the current regulatory structure because the proposed operations are safer than conventional operations using helicopters or fixed wing aircraft which carry an operator and flammable fuel. The proposed flight operations are similar in all material respects to operations already approved by the FAA and are therefore subject to the FAA’s “summary grant” process.

The proposed operations do not create any hazard to users of the national airspace system or pose a threat to national security. The aircraft are battery operated w ith a maximum flight time of less than 50 minutes. The vehicles weigh less than 10 pounds. The vehicles will be operated at or below 400 feet AGL within the visual line of sight of the pilot in command. VCOE’s operations will be over private or controlled access pr operty with the permission of the owner/controller or authorized agent.

Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The proposed UAS carry no fuel, and therefore th e risk of fire following an incident or accident due to fuel spillage is eliminate d. Compared to manned aircraft, the UAS being operated by the petitioner reduces the risk to pa rticipating persons in close proximity to the aircraft due to the limited size, weight, ope rating conditions, and design safety features.

The petitioner’s aircraft have the capability to operate safely after experiencing certain inflight failures, as specif ied in the Manuals. The aircraft are also able to respond to a lost-link event with a pre-coordinated, predicta ble, automated flight maneuver.

2. Specific Limitations on Proposed Flight Operations

Given the small size involved, the restricted e nvironment within which they will operate, the procedures listed below, and pilot certifica tion requirements, VCOE’s proposed operations using the Iris and the Aero would “not create a hazard to users of the national airspace system or the public or pose a threat to nati onal security.” Reform Act Section 333(b)(1).

1. The aircraft weigh less than 10 pounds.

2. Each aircraft will be identified by serial number, registered with the FAA, and have identification (N-N umber) markings as large as practicable.U.S. Department of Transportation Page Six

6 3. Flights will be operated within visual line of sight of the pilot in command (PIC).

4. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by PIC.

5. The PIC will ensure that before each flight, there is enough available power for the UAS to conduct the intended opera tion and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

6. The aircraft will be operated during daylight and in VFR conditions.

7. Flights will not exceed 400 feet AGL.

8. Flights will be operated at a lateral di stance of at least 500 feet from any persons or property not associated wi th the operation who have not given prior permission.

9. Flights will be limited to a groundspeed of 100 mph.

10. Minimum crew for each flight will consist of a PIC and an Observer.

11. The PIC will hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC will also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state or the Federal Government. The PIC w ill also meet the flight review requirements specified in 14 CFR § 61.56.

12. Prior to the flight, a Missi on Plan will be created setting forth the limitations for the flight as well as contact information for the PIC.

13. The flight operations will yield the ri ght of way to other manned aircraft operations.

14. All persons who are not involved with VC OE’s operations will be required to be at least 500 feet fr om flight operations.

15. The aircraft will only operate over privat e or controlled access property with the permission of the owner/controller or authorized representative.

16. The UAS will not operate within 5 nautical miles of an airport unless a letter of agreement is obtained.U.S. Department of Transportation Page Seven

7 17. All required permissions and permits will be obtained from territory, state, county or city jurisdic tions prior to flight.

18. Prior to commencing operations, VCOE w ill obtain a Certificate of Waiver or Authorization (COA) from the FAA.

19. If the aircraft loses communications, it wi ll have the capability to return to a pre-determined location within the operational area and land.

20. If the aircraft loses its GPS signal it will have the capability of being flown manually to a predetermined location w ithin the operati onal area and land.

21. The flight will be aborted in case of unpredicted obstacles or emergencies.

22. UAS operations will be conducted within the parameters of the Manuals.

3. Flight Recovery, Lost Communications, and Lost GPS Procedures

The flight recovery, lost communications, and lost GPS procedures are more fully documented in the attached UAS Manuals.

V. SPECIFIC FAR EXEMPTIONS REQUESTED

VCOE seeks an exemption from several interre lated provisions of 14 C.F.R. Parts 21, 45, 61, and 91 for purposes of conducting the requested ope rations using the Iris and Aero 2. Listed below are (1) the specific FAR sections for wh ich exemption is sought, and (2) the operating procedures and safeguards that VCOE has established which will ensure a level of safety better than or equal to the rules from which exemption is sought. See 14 C.F.R. § 11.81 (e).

A. 14 C.F.R. Part 21, Subpart H – Airworthiness Certificates and 14 C.F.R. § 91.203(a)(1)

The FAA has stated that no exemption is needed from this section if a finding is made under the Reform Act that the UAS selected provides an equivalent level of safety when compared to aircraft normally used for the same appli cation. These criteria are met with this petition, and therefore no exemption is needed. See Grant of Exemption No. 11062, Docket No. FAA 2014-0352 at 13-14, 22. If, however, the FAA determin es that there are some characteristics of the Iris or the Aero that fail to meet the re quirements of the Reform Act, an exemption is requested.

Equivalent Level of Safety : The Iris and Aero are safe when taking into account their size, weight, speed, and operational capability. They weigh less than 10 pounds and will be flown at speeds less than 100 miles per hour, and in visu al line of sight of the operator. The UASsU.S. Department of Transportation Page Eight

8 do not carry pilots, passengers, explosive mate rials, or flammable liquid fuels. The UASs will be operated within the parameters of their respective Manuals.

The proposed operations will be at least as safe as, or safer than, conventional rotorcraft or fixed wing aircraft operating with an airworthiness certificate without the restrictions and conditions proposed here.

B. 14 C.F.R. Part 27 Airworthiness Standards: Normal Category Rotorcraft

14 C.F.R. Part 27 sets forth the procedural re quirements for airworthin ess certification of normal category rotorcraft. To the extent th e Iris or Aero woul d otherwise require certification under Part 27, VCOE seeks an exemption from Part 27’s airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H.

C. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): Aircraft Marking and Identification Requirements

14 C.F.R. §45.23(b), Markings of the Aircraft states:

When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light-spor t category aircraft or experimental or provisionally certificated aircra ft, the operator must also di splay on that aircraft near each entrance to the cabin, cockpit, or pilo t station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light-sport, “experimental,” or “provi sional,” as applicable.

14 C.F.R. § 45.27(a) states:

Rotorcraft. Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

14 C.F.R. § 91.9(c) states:

No person may operate a U.S.-registered civil ai rcraft unless that aircraft is identified in accordance with part 45 of this chapter.

In a previous Grant of Exemption, the FAA determined that exemption from these requirements was warranted provided that th e aircraft “have iden tification (N-Number) markings in accordance with 14 CFR part 45, S ubpart C if the markings are “as large as practicable.” See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 14.U.S. Department of Transportation Page Nine

9 Equivalent Level of Safety : VCOE will mark all Iris and Aero aircraft with their N-Number in a prominent spot on the fuselage with ma rkings that are as large as practicable.

D. 14 C.F.R. § 61.113: Private Pi lot Privileges and Limitations

VCOE seeks exemption from 14 CFR § 61.113, whic h restricts private pilots from flying aircraft for compensation or hi re and would also require a se cond class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the PIC will be operating, as we ll as requiring certifications if the pilot is carrying passengers or cargo for hire.

While the UAS will be operated as part of a commercial operation, they carry neither passengers nor cargo. In the Grant of Exem ption in FAA Docket No. FAA-2014-0352, the FAA determined that the unique characteristic s of UAS operation outside of controlled airspace did not warrant the addi tional cost and restrictions a ttendant with requiring the PIC to have a commercial pilot certificate and a cl ass II medical certificate. The FAA has also determined that the required knowledge for a co mmercial pilot covers the same fundamental principles as a private pilot.

The FAA has also granted exemptions allowi ng operations by people who hold an airline transport, commercial, private, recreational, or sport pilot certificate with a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state or the Federal Government. The PIC must also meet the fli ght review requirements specified in 14 CFR § 61.56. See FAA Exemption No. 11374.

VCOE will ensure the PIC will meet the requir ements listed in the above paragraph. VCOE will also ensure the PIC will have completed the manufacturers’ training guidelines outlined in the Manuals.

The FAA stated in its grant of an exception to Astraeus Aerial the “the FAA considers the overriding safety factor for the limited operatio ns proposed by the petitioner to be the airmanship skills acquired through UAS-specific f light cycles, flight time, and specific make and model experience, culminating in veri fication through testing.” See Exemption No. 11062, Docket No. FAA 2014-0352, at p. 18. The proposed operations can achieve an equivalent level of safety by requiring the knowledge and experience in Iris and Aero operations described above.

The restrictions VCOE has placed on its UAS operations meet or exceed the restrictions similarly imposed on Astraeus Aerial in F AA Docket No. FAA-2014- 0352 and those listed in the FAA’s “summary grant” process.U.S. Department of Transportation Page Ten

10 E. 14 C.F.R. § 91.7(a): Civil Aircraft Airworthiness

VCOE seeks an exemption from 14 C.F.R. § 91.7(a) , which requires that a civil aircraft be in airworthy condition to be operate d. The FAA has stated that no exemption is required to the extent that the requirements of Part 21 are waived or f ound inapplicable. Accordingly, VCOE requests that the requi rements for Section 91.7 be treated in accordance with FAR Part 21 Subpart H. See Grant of Exemption No. 11062, p. 19.

F. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 14 C.F.R. §§ 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration

Pursuant to 14 C.F.R. § 91.9(b)(2):

(b) No person may operate a U.S. -registered civil aircraft -

... (2) For which an Airplane or Rotorc raft Flight Manual is 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.

Pursuant to 14 C.F.R. § 91.203(a) and (b):

(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 curren t airworthiness certificate...

(b) No person may operate a civil aircra ft unless the airwor thiness certificate required by paragraph (a) of this secti on or a special flight authorization issued under § 91.715 is displayed at the cab in or cockpit entr ance so that it is legible to passengers or crew.

VCOE does not request an exemption from this section but instead notifies the FAA that, in accordance with FAA Office of Chief Counsel’s Opinion dated August 8, 2014, the UAS flight manual, registration certificate and othe r documentation will be kept at the control station with the PIC during flight. The Chief Counsel’s Office has held that for all UAS operations, this alternate method constitute s full compliance with the regulations. See also Grant of Exemption No. 11062, pp. 19-20, and Grant of Exemption No. 8607.U.S. Department of Transportation Page Eleven

11 G. 14 C.F.R. § 91.103: Preflight Action

VCOE seeks an exemption from 14 C.F.R. § 91.103, which requires a PIC to become familiar with specific information before each flight, including information contained in the FAA-approved Flight Manual on board the aircraft. The aircraft will not have a Flight Manual on board. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performa nce data before initiation of flight. Under these circumstances, the FAA ha s stated that no exemption is required. See Grant of Exemption No. 11062, p. 20. An exemption is requested to the extent that an FAAapproved Flight Manual is required.

Equivalent Level of Safety: An equivalent level of safety will be provided by following the Manuals. The PIC will take all required preflight actions - including performing all required checklists and reviewing weathe r, flight requirements, batte ry charge, landing and takeoff distance, aircraft performance data, and con tingency landing areas - before initiation of flight. The Manuals will be kept at the ground station with the operator at all times.

H. 14 C.F.R. § 91.109(a): Flight Instruction

VCOE seeks an exemption from 14 C.F.R. § 91.109(a), which provides that “[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully f unctioning dual controls.” UASs and remotely piloted aircraft, by their design, do not have func tional dual controls. Inst ead, flight control is accomplished through the use of the Ground Contro l Station (GCS) that communicates with the aircraft via radio communications.

Equivalent Level of Safety: When flight instruction is performed, no pilots will be on board the aircraft and the GCS will be a safe distan ce from the aircraft and the public, causing no safety hazard. Given the size and speed of the UAS, an equivalent leve l of safe training can still be achieved without dual controls because no pilot or passengers are aboard the aircraft, and all persons will be a safe distance away in the event that the aircraft experiences any difficulties during flight instruction. In addi tion, VCOE will conduct f light training at a remote facility away from popul ation centers. These training flights will comply with the provisions in the Manuals. Accordingly, VCOE ’s proposed method of operation provides superior levels of safety.

I. 14 C.F.R. § 91.119(c): Minimum Sa fe Altitudes in Uncongested Areas

VCOE requests an exemption from the minimu m safe altitude requirements of 14 C.F.R. § 91.119(c). Section 91.119(c) prescribes that an ai rcraft may not be ope rated closer than 500 feet to any person, vessel, vehicle, or structur e. The Manuals provide for VCOE operations at least 500 feet from persons and structures not involved in the operations. The FAA hasU.S. Department of Transportation Page Twelve

12 already determined that relief from Secti on 91.119(c) is warranted for UAS operations in uncongested areas with similar flight re strictions as those imposed by VCOE. See Grant of Exemption No. 11062, p. 20-21.

Equivalent Level of Safety: Compared to flight operations with rotorcraft or fixed wing aircraft weighing far more than the maximum we ights proposed herein, and given the lack of flammable fuel, any risk associated with these op erations is far less than those that presently exist with conventional aircraft. An equivalent le vel of safety will be achieved given the size, weight, and speed of the UAS, as well as the loca tions where it is operated . In order to avoid any risk to aircraft, flight operations will be restricted to 400 feet AGL or below. Other aircraft are already prohibited from operating closer than 500 from structures where VCOE proses to operate. This is airspace where othe r aircraft do not normally operate. As set forth in the Manuals and herein, the UAS will be opera ted in the remote sites, away from persons or structures not involved in the operation. Al l persons who are not i nvolved with VCOE’s operations will be required to be at least 500 f eet from flight operations. This will pose no risk to the public because other airc raft are not operating in these areas.

J. 14 C.F.R. § 91.121: Altimeter Settings

This petition seeks an exemption from 14 C. F.R. § 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight le vel by reference to an altimeter that is set to the elevation of the depa rture airport. The UASs proposed here use both barometric pressure sensors and GPS to determine altitude but do not have the ability to set in a current altimeter setting. An exemption is required to the extent that the UAS does not have a barometric altimeter setting. The altitude of the UAS is monitored by the PIC on the ground control station and by th e visual observer.

Equivalent Level of Safety: The FAA has stated that an equi valent level of safety can be achieved if the aircraft will be operated at orbelow 400 feet AGL and within visual line-ofsight in addition to GPS based altitude info rmation relayed in real time to the operator. See Grant of Exemption No. 11062, p. 20-21. As the attached Manuals indicate, the UAS will be operated at or below 400 feet AGL and otherwise comply with the limitations in the Grant of Exemption No. 11062.

K. 14 C.F.R. § 91.151(a): Fuel Requi rements for Flight in VFR Conditions

VCOE requests an exemption from 14 C.F.R. § 91.151(a)’s fuel requirements for flight in VFR conditions. Section 91.151 states:U.S. Department of Transportation Page Thirteen

13 (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather c onditions) there is enough fuel to fly to the first point of intended landi ng 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 th at for at least 45 minutes.

Here, the technological limitations on the UAS battery power means that no meaningful flight operations can be conducted while mainta ining a 30 minute reserve. The aircraft are battery powered with a maximum flight time of approximately 50 minutes for the Iris and 24 minutes for the Aero. The PIC will ensure that before each flight, there is enough available power for the UAS to conduct the intended operation and to operate after th at for at least five minutes or with the reserve power reco mmended by the manufacturer if greater.

Equivalent Level of Safety: The FAA has stated that an equiva lent level of safety is provided if the UAS flight is conducted under day time VFR flight conditions using VLOS, and terminated with at least 25% rese rve battery power still available. See Grant of Exemption No. 11062, p. 21-22. The FAA’s “summary grant” process provides that the PIC is prohibited from beginning a flight unless th ere is enough available power to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater. See FAA Exemption No. 11374 (FAA Docket No. 2015-0091 at p. 5). The limitations here provide that the PIC will ensure that before each flight, there is enough available power for the UAS to conduct the intended operation and to operate after that for at least five mi nutes or with the reserve power recommended by the manufacturer if greater.

L. 14 C.F.R. §§ 91.405(a) , 91.407(a)(l), 91.409( a)(2); 91.417(a) and (b): Maintenance Inspections

VCOE seeks an exemption from the maintena nce inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 9 1.417(a) and (b). These regulations specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. See

, e.g ., 14 C.F.R. § 91.405(a) (stating that each owner or operator of an aircraft “[s]hall have the aircraft inspected as prescribed in s ubpart E of this part and sha ll between required inspections ... have discrepancies repaired as prescribed in part 43 of this chapter”). An exemption from these regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which th e UAS proposed here will not have.

Equivalent Level of Safety: An equivalent level of safety will be achieved because maintenance and inspections will be perfor med in accordance with the Manuals. This includes maintenance, overha ul, replacement, and prefli ght inspection requirements. SeeU.S. Department of Transportation Page Fourteen

14 Exemption No. 11062 (FAA Docket No. 2014-0352, at p. 14-15) and Exemption No. 11374 (FAA Docket No. 2015-0091, at p. 4).

VCOE will follow the UAS manufacturer’s mainte nance requirements. Flights will not be conducted unless a flight operations checklist is performed that includes all of the aircraft’s components.

VI. PUBLIC INTEREST

Granting VCOE’s petition for exemption furthers the public interest. National policy set by Congress favors early integra tion of UAS into the NAS in controlled, safe working environments such as proposed in this petiti on. By granting this peti tion, the FAA will fulfill Congress’s intent of allowing UAS to operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act.

Moreover, use of UAS will promote science an d technology education for high school and middle school students. The use of the UAS pr opped here will also decrease safety-related incidents involving traditional aircraft. The pub lic has an interest in promoting science and technology education and in reducin g the hazards and emissions a ssociated with alternate use of helicopters and small airplanes to conduct similar operations.

VII. PRIVACY

All flights will occur over private property either owned by VCOE or with the owner’s consent. All flights will be conducted in acco rdance with any federal, state or local laws regarding privacy.

VIII. SUMMARY FOR FEDERAL REGISTER

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determ ined that publication is needed:

VCOE seeks an exemption from the following ru les for aeronautical and UAS training and education of middle and high sc hool students: 14 C.F.R Part 21, Subpart H; 14 C.F.R Part 27; 14 C.F.R § 45.23(b); 14 C.F.R. § 45.27(a) ; 14 C.F.R § 61.113; 14 C.F.R § 91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109(a); 14 C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409( a)(2); 14 C.F.R § 91.417 (a) & (b).

The exemption will promote science and techno logy education and training while enhancing safety by reducing risk to the operator, the general public and property owners from theU.S. Department of Transportation Page Fifteen

15 substantial hazards associated with perfor ming equivalent training and education using traditional conventional ai rcraft and rotorcraft.

VCOE requests that the FAA gran t this petition using the “summa ry grant” process such that publication in the Federal Register is not requ ired. This petition would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

IX. ATTACHMENTS

Attachment 1: IRIS Operation Manual Attachment 2: Aero-M operation Manual

If you have any questions or require any additi onal information, please do not hesitate to contact the undersigned a ttorneys for VCOE Corp.

X. CONCLUSION

Satisfaction of the criteria pr ovided in Section 333 of the Re form Act - size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line of sight, and national security c onsiderations - provides more th an adequate justification for the grant of the requested exem ptions to permit VCOE to operate the UASs proposed here. Furthermore, this petition wa rrants review by the FAA under the “summary grant” process for immediate approval.

Respectfully submitted, Morrison & Foerster LLP Counsel for VCOE

By William D. Janicki William V. O’Connor Morrison & Foerster LLP 12531 High Bluff Drive, Suite 100 San Diego, CA 92130-2040 Telephone: (858) 720-5100 Facsimile: (858) 720-5125 wjanicki@mofo.com woconnor@mofo.com