The University of Texas at Arlington Research Institute

7300 Jack Newell Blvd S Fort W orth, TX 76118 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 1012 (Public Law 112

- 95) Regarding Commercial Employme nt of Unmanned Aircraft Systems (UAS)
To whom it may concern, The Univers ity of Texas at Arlington hereby applies for authorization to Section 333 of Public Law 112

- 95 commonly known as the “FAA Modernization and Reform Act of 2012” or “The Reform Act”, in order to conduct research related activities on unmanned aircraft system s (UAS) within the United States National Airspace System (NAS) in support of research, education, and 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 that publication is needed: The University of Texas at Arlington Research Institute seeks exemption from 14 CFR Part 21, Subpart H; Part 27; 45.23; 61.23 (a) (c); 61.101 (e)(4)(5); 61.113; 61.315 (a); 91.7 (a); 91.9 (b)(2)(c); 91.103 (b)(2); 91.105; 91.109; 91.119 (c); 91.121; 91.151; 91.203 (a)(b); 91.405 (a); 91.407 (a)(1); 91.409 (a)(2); 91.417 (a)(b) to allow employment of Unmanned Aircraft Systems (UAS) in support of research, education and development in a reas such as unmanned systems, human robot interaction, transportation management, emergency response, security, agriculture, and manufacturing. Approval of this exemption request will enhance safety by reducing risk to the general public and property owne rs from the substantial hazards associated with performing equivalent work with conventiona l aircraft and rotorcraft. UTA’s exemption request would permit operation of lightweight, UAS generally in Class G airspace and outside of five miles of an airport point of origin. Each flight will have predetermined areas of operation that will allow UTARI to operate with an equivalent or greater level of safety.
Welook forward to your review of this request and would like to discuss any questions or concerns as th ey arise. Sincerely,

Michael McNair Automation and Intelligent Systems Division Head University of Texas at Arlington Research Institute (UTARI) 7300 Jack Newell Boulevard South, Fort Wo rth, TX 76118 T: 817

-272

- 5852 mcnairmk@uta.edu**Glossary of A** **bbreviations** AGL Above Ground Level FAA Federal Aviation Administration GPS Global Positioning System NAS National Airspace System NM Nautical Mile NPRM Notice of Proposed Rulemaking RTH Return

-to

- Home sUAS Small Unmanned Aircraft System UA Unmanned Aircraft UAS Unmanned Aircraft System UAV Unmanned Air vehicle UTARI The University of Texas at Arlington Research Institute VLOS Visual Line of Sight VO Visual Observer**INTRODUCTION A ND INTEREST OF THE PETITIONER** 

In recent years, the use of Unmanned Aircraft Systems (UAS) has dramatically increased due to the technology developments and the availability of commercial off

-the

- shelf products. It’s an undeniable fact that UAS technology benefits various applications areas, including government entities. Sample a pplications of UAS range from water conservation, oil/gas exploration, agriculture, law enforcement, fi refighting, transportation monitoring, and entertainment, and others. As the use and number of UAS are increasing, safe operation solutions of such aircraft systems in the National Airs pace System (NAS) beco me more and more important. The University of Texas at Arlington (UTA) and the Automation and Intelligent Systems (AIS) Division at the University of Texas at Arlington Re search Institute (UTARI) focus on research in navigation, safety, collaborative and swarm behavior, control methods, communication uncertainties, rapid conflict avoidance, automatic emergency landing, low

- cost UAS tracking, and sense/detect/ avoid systems for UAS. Results from our rese arch will help to develop knowledge and methods t hat increase the efficiency of UAS operations in a safe manner. UTA is requesting support to perform small UAS operation s in the national airspace for research, education, and development purposes. The outco me of th is research will be beneficial for government and non

government entities in a wide range of applications and operations that will lead to the benefit of society at large. The remainder of this document details our exemption request and identifies the specific areas where we are requesting a waiver. For convenience, hyperlinks to the following sections are available here:

 Overview Characteristics of Proposed UA

 Qualification for Approva l Under Section 333 of the Reform Act

 Specific Sections of 14CFR from which Petitioner Seeks Exemption or Relief

 Wh y Granting this Petition is in the Public Interest

 Summary of Regulations from which Petitioner Seeks Exemption or Relief

 Supporting and Technical Documents**OVERVIEW CHA RA** **CTERISTICS OF PROPOSED UA**

**UA and platform restrictions**  The Unmanned Aircraft (UA) flown under this exemption will include multi rotor, fixed wing, and dirigible type Unmanned Aircraft Systems (UAS). They will be maintained and operated in compliance with FAA regulations, FAA Modernization and Reform Act Section 333 exemptions , and UTA requirements. The specific waivers and adherence to these is identified and requested in this document. All UA used in UTA operations will :

- be limited to below 55 pounds at takeoff including airframe and all payload

. Typical UTA UA are below 15 pounds ;

- be limited in their physical size. UTA UA will generally not exceed two by two by two meter in dimension ;

- be limited to speeds below 100 miles per hour. UTA UA are typically flown below 30 miles per hour;

- be battery powered and use electric motors for propulsion. UTA UA almost exclusively use lithium polymer batteries for their charge density and light weight as opp osed to flammable liquid fuels;

- Have a base frame made out of sturdy materials. These will typically include some combi nation of aluminum, steel, carbon fiber, and high strength plastics such as nylon. UTA UA, in support of research and student competition teams, are almost exclusively aluminum and carbon fiber frame platforms, but also include light weight plywood and fo am that may be plastic reinforced. **Required Platform Operating Documents** All purchased UTA UAS are sold with supporting documentation to include information on operation and maintenance of the vehicle . These documents will help comprise the Operating Documents of the platform. UTA may supplement the manufacturers’ documents for ease of use for system function s of the platform. The resulting documentation set will include the following items and features , as applicable:

- An operations manual. The documents must explain how to properly and safely operate the UAS and explain all of its features and controls;

- A maintenance Manual. The documents must explain how to perform all regular maintenance along with recommendations for frequency of checks and required maintenance detection;

- A safe operation checklist. This will enable UTARI staff to test that a UAS is in working order at any moment;

- A safe pre

-flight checklist. This will enable and actively encourage users to test that the UAS is in working order and safe condition right before an operation in the NAS;

- How to read the altitude of the UA. This will enable The Operator to verify that the UA is under the 400 foot limit for UAS operations during flight ;

- Reading orientation markings or lights. The Operator and any VO must keep the UA in naked eye sight at all times and be mindful of the orientation and heading. The documents must explain how to properly read the visual orientation markers or lights on t he platform;

- Reading remote battery indicator. The documents must explain how to properly read the UA battery level from the Ground Control S tation in order to end the ope ration at a safe battery level;

- Lost communication and GPS behaviors. The documents must explain the UAS’s behaviors when communication is lost between the UA and Ground Control S tation or the UAS loses GPS signal. **Summary**

**of current UA**

**s**The following table identifies the vehicles currently owned by UTA that would initially be covered under

this exemption request. Other vehicles meeting the approved exemption may be added in the future.
Manufacturer/Model 3DR X8 Penguin 1720

- Finwing Air Titan 2520

- Finwing Aircraft type Mu ltirotor (8 rotors) Fixed W ing Fixed W ing Aircraft We ig ht 5.6 lb. 2.4kg 7.0kg Dimensions .51 x .35 x .2 meters 1720MM W ing Span 2520MM W ing Span Flight Time (approx.) 15 minutes 30 min utes 45 min utes Propulsion Brushless Electric motor Brushless Electric Motor Brushless Electric Motor Power Storage 14.8 VDC LiPo battery 14.8 VDC LiPo battery 14.8 VDC LiPo battery Airframe Material Aluminum Foam Construction Foam Construction
UTA’s 3DR X8 UA is an octa

- copter that cannot exceed 10 pounds at maximum payload during takeoff or flight. Its estimated occupied volume is less than 0.05 m 3 far smaller than any traditional manned aircraft. The UA has a recommended flight speed of only 11 miles per hour and is powered by a lithium polymer battery that does not have the same level of risk as flammable fuel. The 3DR X8 has a rigid aluminum frame that can hold the payload securely. 3DR has extensive documentation on the X8 platform including instructions on flight and battery safely, battery charging, failsafe systems, Ground Control S tation setup, flight modes, takeoff and l anding, status indicators, and m aintenance. The X8 has marked front rotor arms to indicate its infl ig ht heading to t he Operator and VO. The X8 ground station gives location, altitude, battery level, and other information to the PIC. In the event of lost link or lost GPS signal the X8 can be set to use three different automated emergency modes including fly home and land, reach specified al titude return home and land, and land in place. There is a geo fencing mode available with the platform that can automatically limit the flight volume including a 328 foot ceiling.**QUA LIFICA**  **TION FOR A PPROVA** **L UNDER SECTION 333 OF THE REFORM A CT** 
The proposed operations in this petition for exemption qualify for 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 of small , relati vely low cost, and consumer available UAS u nder controlled conditions in limited and predetermined airspace and would provide an increased level of safety beyond that existing when fixed or rotor wing manned aircraft are used to accomplish the same purpose

. UAS o perations include vehicles that are typically less than fifteen pounds and never exceed fifty five pounds. UA will almost exclusively operate below 30 miles per hour and never exceed 100 miles per hour

. A trained UAS Operator will perform the operations and maintain line of sight with any VOs so that they do not create any harm to the public or interference with the NAS. These operations are limited in scope and range and will have an equivalent level of safety as envisioned and communicated by Congress that the FAA must allow by exception. This exemption will not pose any threat to national security, the NAS, or the general public. It will be a public benefit by increasing growth of the commercial sector , support resea rch, e ducation and development, and reduce environmental impacts in comparison to traditional aircraft. The following list of limitations and conditions must be followed by UTA to include its staff, faculty and students under UTA sponsored operations and under this FAA exemption
1. Operations authorized by this grant of exemption are limited to rotor , fixed wing, and dirigible aircraft. 2. UA (aircraft and payload) will weigh less than 55lbs. 3. UA will be operated at altitudes not greater than 400 feet AGL. Altitudes , when reported to ATC , will be in feet AGL. 4. UA will be flown at ground speeds not greater than 100 miles per hour. 5. The UAS Operator will receive training from UTA on UAS flight operations , 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 territory, a possession, or the Federal government. 6. In addition to holding an FAA issued airman medical certificate, the UAS Operator must complete a UTA UAS Training Program. This t raining will include : a. A detailed review of manufacturer's operating manuals. b. A practical demonstration of ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption. c. M aintaining appropriate distances from persons, vehic les, vessels and structures. d. Operator qualification will have a currency requirement of at least three take

- offs and landings within the preceding 90 days e. How to keep mainte nance and flight logs. All UTA ope rations and maintenance to U TA UA will be logged in accordance to 14 CFR § 61.51. f. Ma intaining a safe distance from related and non

- related structures, vehicles, and people. g. Battery monitoring and landing. h. Limitations and error in human perception. i. Emergency and evasive maneuvers and giving the right of way to all other unrelated aircraft, vehicles, and people. 7. UA will not be operated within 5 nautical miles (NM) of an airport center of origin having an operational control tower, or 3 NM of an airport center of origin with a publi shed instrument flight procedure but not an operational control tower, or 2 NM of an airport center of origin without a published instrument flight procedure or operational control tower, or 2 NM of a heliport with a published instrument flight procedure. Flights will only be operated in Class G airspace . Ifoperation 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 flights will o perate 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. The UA will remain clear of and yield right of way to manned aviation op erations. 11. UA will be operated within visual line of sight (VLOS) of the Operator at all times The Operator will use human vision unaided by device other than corrective lenses. 12. UAS operations m ay employ a visual observer (VO) if the UA is to be flown at a range to which human perception may make discerning orientation properly difficult . The VO may be used to satisfy the V L OS requirement as long as the Operator maintains VLOS capability. The VO and Operator must be able to com municate verbally for the duration of the flight

. Electronic messaging or texting by either the Operator or VO is not allowed during flight operations. 13. The VO will perform no duties other than assisting the Operator see and avoid other aircraft, obstacles , persons or property. 14. UAS will be equipped with an autopilot system which will be at least capable of all the functions described in this request . The UAS will utilize GPS navigation, failsafe’s, return

-to

- home (RTH) and flight abort safety features. 15. Prior to each flight the Operator 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 o peration 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. 16. All UAS operations will be conducted over open waters and sparsely populated private or public property. Permission for flight will be sought in advance from property owners or controlling agency. A Ground Control Station will be connected, by radio communication, to the UAS during the entire flight, which will give the Operator flight information such as GPS Position, Altitude, Air speed, Battery Remaining, and other telemetry information. 17. Flight boundaries will be established fo r 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. 18. If the UAS loses communications or loses GPS signal, the UA will return to a predetermined locatio n within the established flight boundary and land , land in place, or be recovered in accordance with manufacturer's operations documents. 19. The Operator will abort any flight in the event of unpredicted obstacles, occurrence of adverse weather or loss of UAS flight control capability in accordance with manufacturer's operations documents. 20. The Operator is prohibited from beginning a flight unless (considering wind and forecast conditions) there is enough power to fly the planned operation to the intended lan ding point and land the UAS with 25% of useable battery capacity remaining. 21. Documents required by 14 CFR § 91.9 and 91.203 will be available to the Operator at the Ground Control Station of the UAS whenever the aircraft is operating These documents will b e made available to the Administrator or any law enforcement official upon request. 22. Before conducting flight operations, the radio frequency spectrum used for operation and control of the UA must comply with Federal Communications Commission (FCC) or othe r appropriate government oversight agency requirements. 23. A Flight Operations and Maintenance Log will be maintained for each UAS. Cumulative flight hours, maintenance activities, repairs, alterations and inspections will be noted. 24. Any UAS maintenance or alterations that affect UAS operation or flight characteristics, e.g. replacement of a flight critical component, must un dergo a functional test flight t he Operator who conducts the functional test flight must make an entry in the Flight Operations and Mai ntenance Log.**SPECIFIC SECTIONS OF 14 CFR FROM WHICH PETITIONER SEEKS EXEMPTION**  **OR RELIEF 14 CFR Part 21,**  **Subpart H: A irw**  **orthiness Certificates** Sets forth requirements for procurement of necessary airworthiness certificates.
The FAA has stated that no exemption is needed from this section if a finding is made under Part 11 and Section 333 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 consideration of the size, weight, speed, and limited operating area associated with the aircraft(s) and their operation , 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 Rotorc raft

. Sets forth the procedural requirements for airworthiness 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 t he request for exemption from 14 CFR Part 21, Subpart H.
**14 FR §**  **61.23 (a) & (c)** Sets forth medical certificate requirements for different exercised permissions. All UAS personal in UTA operations will hold either 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 territory, a possession, or the Federal government. The FAA has issued many exemptions to this regulation, see Exemption Nos. 11213, 11252, 11275, 11277, and 11278

. **14 CFR § 45.23 (a)(b)**  Marking of the Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. UAS do not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to place on such small aircraft. UTARI will mark all UASs with a registration number or N number as large as practicable were it can easily be found on the UA

. The UAS G round Control S tation will also keep a copy of all required markings and identification numbers. The FAA has issued many exemptions to this regulation, see Exemption Nos. 8738, 10167, 10167A and 10700. **14 CFR § 61.101,**  **61.113 , and**  **61.315** Recreational pilot privileges a nd limitations, Private and Commercial Pilot Privilege and Limitations , and what are the privileges and limits of my sport pilot certificate respectfully. The proposed UAS are small, lightweight, and relatively slow. They do not hold a pilot, passengers, or cargo (other than operational payload). They can employ a high degree of automation to complete technical tasks with a reduced margin of error while grou nd crews maintain situational awareness. As stated in the FAA NPRM on sUAS “the FAA believes that the training, testing, proficiency and experience requirements for obtaining a commercial pilot license have limited relevance to the nature of small UAS operations” and “the FAA decided that imposing such requirements ” of a pilots license

“would be unduly burdensome to small UAS operators”. It is the petitioner’s belief that these statements are true and that UAS operators will receive training from UTA and carry a government issued driver’slicense in order to operate without any form of FAA pilot’s license that would largely be non - relevant to

their operations. **14 CFR § 91.7 (a)**  Civil Aircraft Airworthiness. Stipulates (a) No person may operate a civ il aircraft unless it is in an airworthy condition. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation requires exemption. **14 CFR § 91.9 (b)(2)**  Requires that there is available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual

. As there are no pilots or passengers, and given the size of the UAS, this Regulation is not applicable

. An equivalent level of safety will be achieved by m aintaining a manual at the UAS Ground C ontrol Station . The FAA has issued many exemptions to this regulation, see Exemption Nos. 12104, 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 32827. **14 CFR § 91.9 (c)**  Stipulates No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter. As stated above ( 14 CFR § 45.23 (a)(b) ) the UA will not be marked in accordance with manned aircraft regulations but will be marked with a registration number or N number. The UAS ground station will also keep a copy of all required markings and identification numbers. The FAA has issued many exemptions to this regulation, see Exemption Nos. 8738, 10167, 10167A and 10700. **14 CFR § 91.103 (b)(2)**  Requires an aircraft flight manua l in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual at the UAS Ground Control Station

. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 10700 and 32827. **14 CFR § 91.109**  Stipulates, in part, that (a) No person may operate a civil aircraft (except a manned free balloon) t hat is being used for flight instruction unless that aircraft has fully functioning dual controls Regulation is n on - applicate as by design UA do not have fully functioning dual controls. Flight control is accomplished through the use of a control interface that 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 many exemptions to this regulatio n, see Exemption Nos. 11066, 11062, 1067A and 11065. **14 CFR § 91.119 (c)**  Minimum Safe Altitudes. Stipulates, in part, that, except when necessary for takeoff or landing, no person may operate an aircraft below specific altitudes. Exemption is required because UAS operations will be conducted at altitudes no greater than 400 feet above the surface. The size, speed, weight and limited operational parameters of the UAS allow for an equivalent level of safety. **14 CFR § 91.121** Altimeter Setting s. Specifies altimeter initialization and reporting.

Altitude will be measured either by barometric sensor or electronic global positioning systems and internal gyroscopes to provide spatial coordination. This will report an AGL altitude readout and will provide an equivalent level of safety. The FAA has issued several exemptions to this regulation: see Exemptions Nos. 12656, 11066, 11065, 11062 and 11063. **14 CFR § 91.151**  Fuel Requirements for Flight in VFR Conditions. Stipulates that (a) No person may begin a flight in an airplane or rotorcraft under VFR conditions unless they can reach the point of intended landing with various amounts of extra flight time fuel. This incl udes 20 extra flight minutes of fuel for rotorcraft. For the majority of UA t his would include most if not more than all of the ir total fight time and would effectively deny their operation. Under this petition UTA UA would not be permitted to fly unless (including wind and forecast conditions) the operation could be performed with 25% of the usable battery capacity remaining in reserve. This restriction would be more than adequate to return the UA to its planned landing zone from anywhere in its limited operating area and provide an equivalent level of safety . The FAA has issued several exemptions to this regulation: see Exemptions Nos. 12656, 2689F, 5745, 10673 and 10808. **14 CFR § 91.203 (a) & (b)**  Requires for the carrying of civil aircraft certifications and registrations within the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this regulation is inapplicable. An equivalent level of safety will be achieved by maintaining records at the UAS Ground Control Station. **14 CFR § 91.405 (a), 91.407 (a)(1), 91.409 (a)(2), 91.417 (a) & (b)**  Ma intenance Inspections. These regulations require, amongst other things, aircraft owners and operators to "have [the] aircraft inspected as prescribed in subpart E of this part a nd shall between required inspections, except as provided in paragraph C of this section, have discrepancies repaired as prescribed in part 43 of this chapter." These regulations require an airworthiness certificate that will not exist. An equivalent 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. 12656, 11066, 11062, 11067A and 11065.

**WHY GRA NTING THIS PETITION IS IN THE PUBLIC INTEREST**  The requested exemption would authorize the University of Texas at Arlington , to include the UTA Research Institute and UTA faculty, to work towards serving the greater public good. UTA’s planned research activities on Unmanned Aircraft Systems (UAS) include but is not limited to development of guidance, navigation and control systems, sense/detect and avoid methods, autonomous navigat ion with obstacle avoidance, collision avoidance, assistive safety technologies for pilots, fault tolerant control systems, intelligent navigation techniques in GPS

- denied environments, and moving object detection, and identification and tracking systems. The research on these topics will be beneficial for government entities such as Department of Agriculture, Department of Transportation, State and Local Law Enforcement, Federal Emergency Management Agency for applications including, but not limited to, area surveillance, traffic, railroad, and highway surveys and monitoring, customs and border patrol, crash scene investigation, highway patrol, area security surveillance, firefighting, wildfire management, farm management, wildlife tracking and accounting i n remote areas, 3

- D terrain mapping, disaster area surveys and assessment, search and rescue operations. Approval of this exemption would therebyenhance safety and help to fulfill the Secretary of Transportation’s responsibilities under Section 333(c)

of the Reform Act to "establish requirements for the safe operation of such aircraft systems in the national airspace system". Approval of this exemption will allow for safer, more efficient and less costly UAS operations, and produce much higher benefits to general public.**SUMMA RY OF REGULATIONS FROM WHICH PETITIONER SEEKS EXEMPTION**  **OR RELIEF 14 CFR Part 21, Subpart H 14 CFR Part 27**  **45.23 (a)(b) 61.23 (a) & (c)**  **61.101 (e)(4) & (5) 61.113**  **61.315 (a) 91.7 (a)**  **91.119 (c) 91.121**  **91.151 91.405 (a)**  **91.407 (a)(1)**  **91.409 (a)(2) 91.417 (a) & (b)**  **91.9 (c) 91.9 (b)(2)**  **91.203 (a) & (b) 91.103 (b)(2)**  **91.109 SUPPORTING A** **ND TECHNICA L DOCUMENTS** 

To be available for reference and review: UTARI 3DR X8 Pilot Operating Manual UTARI AscTech Pelican Pilot Operating Manual UTARI sUAV Specifications and Logbooks UTARI MCE sUAS SOP all aircraft