AUSLEY MCMULLEN 

ATTORNEYS AND COUNSELORS AT LAW 

123 SOUTH CALHOUN STREET 

P.O. BOX 391 (ZIP 32302) 

TALLAHASSEE, FLORIDA 32301 

(850) 224 -9115 FAX (850) 222 -7560 www.ausley.com 

April 1, 2015 

Via Electronic Submission 

Docket Operations 

U.S. Department of Transportation 

West Building, Ground Floor 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Re: Request for `Blanket" COA under FAA Interim Policy 

Applicant: Florida State University 

Docket No.: FAA -2015 -0621 

Dear Sir or Madam: 

Please accept this letter as a supplement to the exemption request submitted by the Center 

for Disaster Risk Policy at Florida State University (the "Applicant "). The Applicant's 

exemption request is currently pending under Docket Number FAA -2015 -0621. 

On March 24, 2015, the FAA announced that it has implemented a new policy of 

granting "blanket" COAs to applicants requesting exemptions from the Federal Aviation 

Regulations under Section 333 of the FAA Modernization and Reform Act of 2012. The details 

of the FAA's policy announcement are set forth in the Press Release enclosed as Attachment 1. 

The Applicant hereby requests that a "blanket" COA that conforms to the terms set forth 

in Attachment 1 upon approval of the Applicant's exemption request. 

Richard E. Doran 

Steven M. Hogan 

Ausley McMullen 

Attorneys for the Center for Disaster Risk 

Policy, Florida State University 
ATTACHMENT 

1 
3/31/2015 FM Streamlines OAS COAs for Section 333 

Federal Aviation Administration 

FAA Streamlines UAS COAs for Section 

333 

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News type: News & Updates 

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The Federal Aviation Administration has established an interim policy to speed up airspace 

authorizations for certain commercial unmanned aircraft (UAS) operators who obtain Section 

333 exemptions. The new policy helps bridge the gap between the past process, which 

evaluated every UAS operation individually, and future operations after we publish a final 

version of the proposed small UAS rule. 

Under the new policy, the FAA will grant a Certificate of Waiver or Authorization (COA) for flights at or 

below 200 feet to any UAS operator with a Section 333 exemption for aircraft that weigh less than 55 

pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual line of sight 

(VLOS) of the pilots, and stay certain distances away from airports or heliports: 

5 nautical miles (NM) from an airport having an operational control tower; or 

3 NM from an airport with a published instrument flight procedure, but not an operational tower; or 

2 NM from an airport without a published instrument flight procedure or an operational tower; or 

2 NM from a heliport with a published instrument flight procedure 

The "blanket" 200 -foot COA allows flights anywhere in the country except restricted airspace and other 

areas, such as major cities, where the FM prohibits UAS operations. Previously, an operator had to apply 

for and receive a COA for a particular block of airspace, a process that can take 60 days. The agency 

expects the new policy will allow companies and individuals who want to use UAS within these limitations to 

start flying much more quickly than before. 

Section 333 exemption holders will automatically receive a "blanket" 200 foot COA. For new exemption 

holders, the FM will issue a COA at the time the exemption is approved. Anyone who wants to fly outside 

the blanket parameters must obtain a separate COA specific to the airspace required for that operation. 

Get more information on the FAA and UAS (http: //www.faa iov /about/initiatives /uas/) on our website. 

IHtpJAvww.faa.gov/news/updates/?ne.vsld=82245 12 
3/31/2015 FAA Streamlines UAS COAs for Section 333 

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