Dr. Jessica Scott

dba Scott Sciences

506 71st Ave #2

St. Pete Beach, FL. 33706

727-638-4488

September 28, 2015

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

West Building Ground Floor Room W12-140

Washington, DC 20590

Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11

of the Federal Aviation Regulations

Dear Administrators,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and

14C.F.R. Part 11, Dr. Jessica L. Scott, of Scott Sciences, LLC, a private pilot and sUAS owner,

hereby applies for an exemption from the Federal Aviation Regulations (“FARs”) listed in section

2 to allow commercial operation of the small Unmanned Aircraft Systems (sUAS) listed below

within the Continental United States (CONUS) so long as operations are conducted under the

limitations outlined herein or as may be established by the FAA as required by section 333.

The requested exemptions would authorize commercial operations for environmental inspections,

real estate surveillance, structural inspections, and aerial photography that could be performed more

safely within the U.S. National air space than with the use of manned aircraft. The approval of this

request will, in part, allow improved predictive indicators of crop stress to assist production design,

predictive crop yields, overall water use reduction, pest control, nutritional input management, repair

assessment of structural systems, and beneficial usage from general photography. Operations will

be performed only on owned property or with the authorization and permission of other property

owners or their authorized agents.

Given the small size, weight, speed, and limited operating area of the sUAS involved, and the

remote and restricted environment within which they will operate, approval of the application

presents no national security issue. Due to the reduce environmental impact from several aspects and

the strong level of safety surrounding the proposed operations associated with allowing sUAS for

commercial operations, it can be assured that granting these requested exemptions is in the public

interest (see section 4 below).

The limitations outlined in this request, provide for at least an equivalent or even higher level of

safety to operations under the current regulatory structure because the proposed operations represent

a safety enhancement to employees, ground personnel, or pilot and crew operations that would

otherwise be conducted with conventional aircraft, and because of the very high level of safety

standards outlined in the operating conditions below (see section 5 below).

Therefore, the applicant respectfully requests that FAA grant the requested exemption without delay.
 Table of Contents

Operating Conditions..............................................................................2

sUAS Description....................................................................................3

Name and address of applicant..................................................................4

Section of 14 CFR from which and exemption is being requested......................4

The extent of relief being sought and the reason for the relief ..........................5

How this request would benefit the public as a whole ....................................5

Reasons why granting this exemption would not adversely affect safety .............5

Federal Registry summary .....................................................................6

Appendix A ........................................................................................7

Operating Conditions:

Grant of the exemption would be subject to the following operating conditions and mostly operated

in the Southeastern United States in accordance with conditions set forth by the Academy of Model

Aeronautics and by a Pilot In Command (PIC) who:

Maintains a minimum Private Pilot certificate operating the sUAS with the knowledge of

regulations as they pertain to safety and airspace restrictions afforded by this privilege.

Has a valid driver’ license.

Completed the manufacturer provided training program.

Maintains visual line of sight of the aircraft throughout its operation by unaided human vision

other than corrective lenses as specified on the FAA airmen medical certificate.

Ensures the flight would be discontinued if a hazard to other aircraft, people, or property existed.

Assesses weather conditions, airspace restrictions, and location of people to lessen risks if

accidental loss of control should occur. Potential landing areas in the event of an emergency would

be identified.

Ensures flight would not occur over people except those directly responsible for the flight.

Ensures flights would be limited to 400 feet altitude.

All flights will be operated during daytime VFR conditions.

Ensures flights would remain out of airport flight paths and restricted airspace areas, and obey

FAATemporary Flight Restrictions (TFR’s).

Ensures no objects will be dropped from the sUAS.

Performs pre-flight safety inspections according to the manufacturer including verification of

communications links.

- Maintains the sUAS in optimal condition according to manufacturer recommendations and
continual upkeep of wear or damaged components.

Performs a functional flight test prior to conducting further operations under this exemption

whenever critical flight components have been replaced that would affect the sUAS operation or

flight characteristics. Flight tests would remain at least 500 feet from other persons and be

conducted in such a manner so as not to impose an undue hazard to persons and property.

Utilizes a Visual Observer (VO) in order to identify other aircraft and objects in the airspace

during

the flight so that the sUAS will be the first to maneuver away.

Ensure operations conducted within five miles from an airport shall only be initiated when the

following conditions are met:

* Airport is not a medium or large airport.

* Coordination with the airport authority, or air traffic control when a control tower is

present.

*Airport UNICOM frequency when applicable is monitored and flight intentions are

communicated.

* Flight maneuvers will be initiated to remain clear of traffic as visually observed or when

communicated on the UNICOM frequency by the pilot or control tower.

Will not operate the sUAS from any moving device or vehicle.

The sUAS will be operated at speeds under 40 knots.

The sUAS will not be operated in winds exceeding 25 knots and consistent with any manufacturer

recommendations.

Flight time will be limited in duration to ensure that no less than 10% battery power remains upon

landing.

Verifies that if the sUAS loses communications or loses its GPS signal, it can return to a

pre- determined location and land within the private or controlled-access property.

All operations shall comply with required permissions and permits established by territorial, state,

county, or city jurisdictions; including local law enforcement, fire, or other appropriate

governmental agencies.

sUAS Description:

The following sUAS aircraft are being requested for approval with this petition.

A) DJI Phantom 3:

Features of the DJI Phantom 3 include:

! Based on the highly successful consumer grade Phantom line of DJI quadcopters.

! Battery powered quad rotor unmanned aircraft and handheld ground control station.

! Maximum diameter of less than 24 inches.

! Take-off weight of approximately 2.8 pounds.

! It has fail safe modes of operation for either loss of RC or GPS signal.

! Automatic termination of flight and landing will be initiated when the battery reaches a

predetermined low state.

! Limited range governed by the battery for an approximate 25 minute operational time.

! Load carrying capacity limited to a single sensor approximate to the size of a consumer

point-and-shoot camera

! Maximum speed less than 32 knots.

! Internal inertial measuring unit (IMU) with integrated barometric sensor augmented with global

positioning system (GPS) to maintain geospatial orientation and position.

! Telemetry information is transmitted back to a ground control station allowing the PIC to
monitor battery level, GPS signal strength, altitude (AGL), distance from PIC.

! Altitude can be limited by the onboard flight controller and maximum altitude can be

preprogrammed by the PIC.

1) Name and Address of Applicant is:

Dr. Jessica Scott

Scott Sciences

506 71st Ave #2

St. Pete Beach, FL. 33706

2) Section of 14 CFR from which and exemption is being requested:

a. Exemption of the following sections of 14 CFR are be requested.

• 14 C.F.R. 21 Certification Procedures for Products and Parts

• 14 C.F.R. 61.113(a) Private Pilot privileges and limitations

• 14 C.F.R. 91.7(a) Civil Aircraft Airworthiness

• 14 C.F.R. 91.119(c) Minimum safe altitudes

• 14 C.F.R. 91.121 Altimeter settings

• 14 C.F.R. 91.151(a)(1) Fuel requirements for VFR flight

• 14 C.F.R. 91.405(a) Maintenance Required

• 14 C.F.R. 91.407(a)(1) Operation after Maintenance, Rebuilding, or Altercation.

• 14 C.F.R. 91.409(a)(1)&(2) Inspections

• 14 C.F.R. 91.417(a)&(b) Maintenance records

3) The extent of relief being sought and the reason for the relief:

a. See Appendix A

4) How this request would benefit the public as a whole:

a. Utilizing sUAS in the environmental consulting industry for precision surveys, real estate

surveillance and monitoring, structural inspections, and aerial photography, is in the public

interest because it provides timely access to large amounts of survey data via environmentally

friendly means. This enables private clients as well as government agencies to access photos,

videos, and real time data in order to achieve environmental and construction objectives.

Alternatives to utilizing sUAS technology are increased cost and lack of data precision. These

alternatives might include satellite imagery which is less competitive and is not often available

in the instantaneous time frames needed to detect and react to environmental issues. Manned

aerial survey is another alternative which employs the use of full size aircraft. While the results

can be similar, the process comes at a much higher cost and a more time consuming process. This

process is less able to operate safely close to the ground where higher resolution detail is

needed. Additionally, the proposed sUAS operate off of stored electric energy, reducing the

environmental impact from engine emissions and hazards associated with stored onboard fuel in

the aircraft. A third alternative includes ground scouting analysis which involves personnel

visually inspecting groundcover. This process is very limited by the amount of area a person can

cover on foot over a period of time and areas unaccessible due to dense vegetation – again reducing

the value and increasing the cost of the results as compared to sUAS technology. In addition,

utilizing sUAS technology provides visual inspection of environmentally sensitive areas without

disturbing wildlife habitats, vegetation, wetlands, etc.
In summary, approval of this exemption for commercial operations is in the best public interest

by:

- Assisting with land management and environmental monitoring through increased efficiency and

reduced cost.

- Reduced environmental impact from the reduction in emissions that are traditionally created

from manned flights performing the same task.

- Improved safety of the general public when compared to the hazards associated equivalent

manned flights at low altitudes.

- Providing images of areas which are not easily accessible by foot. 

5) Reasons why granting this exemption would not adversely affect safety and how the

exemptionwould provide a level of safety at least equal to the existing rule.

a. The proposed operations outlined in this petition would not adversely affect safety and will

provide a greater level of safety than the existing rule for the following key reasons:

i. The sUAS would be operated by a certificated pilot with current medical who utilizes the

knowledge of airspace regulations and flight safety to ensure the operation of sUAS is

consistent with these requirements and the safety of fellow pilots of manned aircraft.

ii. The operation of small battery powered sUAS, weighing less than ten pounds, flying at

speeds less than 40 knots, and conducted in the strict conditions outlined in the

Operating Conditions listed above, will provide a higher level of safety than existing

rule utilizing manned aircraft and that of the currently proposed rules for small

unmanned aircraft systems. Conventional operations conducted with manned aircraft

have elevated risks for the following reasons:

1. Operations are in large aircraft carrying large amounts of fuel and operating at

extremely low altitudes while in close proximity to people, animals, and

structures. The opportunity for emergency landings in event of aircraft failure

are limited because of these operating conditions and therefore put the public

in danger.

2. Manned aircraft equipped for the operations requested in this exemption have

a flight crew on board to operate the imaging equipment. The aircraft, pilot,

and crew must travel from an airport to the target area, fly multiple passes

across the surveillance area, and return to the airport. These flights must pass

over many property owners to achieve their objective. This exposes both flight

crew and ground personnel to noise, emissions, and safety risks associated

with such operations.

In summary, the sUAS proposed in this exemption are battery powered, small, lightweight, hand

carried to the surveillance sight (not flown), and operated by a certificated pilot. These safety

enhancements virtually eliminate the risks outlined above and provide for a level of safety better

than the existing rule.
6) Federal Registry Summary

Pursuant to 14 C.F.R. § 11.81(f), the following summary is provided for publication in the

Federal Register, should the FAA determine that publication is needed:

Docket No.: ________________

Petitioner: Dr. Jessica Scott

Sections of 14 CFR: 14 C.F.R. 21, 14 C.F.R. 61.113(a), 14 C.F.R. 91.7(a), 14 C.F.R.

91.119(c), 14 C.F.R. 91.121, 14 C.F.R. 91.151(a)(1), 14 C.F.R. 91.405(a), 14 C.F.R.

91.407(a)(1), 14 C.F.R. 91.409(a)(1)&(2), 14 C.F.R. 91.417(a)&(b)

Description of Relief Sought: Dr. Jessica Scott, Scott Sciences, is seeking an exemption pursuant

to 14 CFR and Section 333 of the FAA Modernization and Reform Act of 2012. The exemption

will permit safe operation of the above name sUAS commercially for the purpose of precision

surveys, real estate surveillance and monitoring, structural inspections, and aerial photography

that could be performed more safely within the U.S. National air space than with the use of

manned aircraft.

Based upon the foregoing, Dr. Jessica Scott, Scott Sciences, requests that the FAA grant the

necessary exemptions under Section 333 of the FAA Reform ACT and 49 U.S.C. §44701(f) of

the Federal Aviation Act as requested herein to allow commercial operations within the

continental United States.

Submitted on September 28, 2015

Respectfully submitted,

Dr. Jessica L. Scott
APPENDIX A: The Extent of the Relief being Sought and the Reason for the Relief

Dr. Jessica Scott, requests an exemption from the regulations listed in section 2 to the extent

described below as well as any additional regulations that may technically apply to the operation

of the aircraft:

14 C.F.R. Part Part 21, Subpart H: Certification Procedures for Products and Parts,

Subpart H – Airworthiness Certificates

Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements

for the issuance of airworthiness certificates as required by FAR § 91.203(a). Given the size of

the sUAS, its weight, speed, operational capability, its proximity to airports and populated areas,

and the operating conditions outlined in this petition, it is unnecessary to go through the

certificate of airworthiness process under Part 21 Subpart H in order to achieve or exceed current

safety levels.

Such an exemption meets the requirements of an equivalent level of safety under Part 11 and

Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act

both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate,

upon the consideration described herein.

14 C.F.R. § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command

Section 61.113(a) limits private pilots to non-commercial operations. Unlike a conventional

aircraft that carries a pilot, passengers, and cargo, the sUAS in this petition are remotely

controlled with no passengers or property of others on board. Section 61.133(a) requires an

individual with a commercial pilot’s license to be pilot in command of any aircraft for

compensation or hire. While airspace knowledge and requirements remain the same for both

private and commercial pilots, and while sUAS do not present the safety hazards around

non-airspace issues such as on-board occupants, it is an equivalent level of safety for private

pilots to serve as pilot of command of a sUAS for compensation or hire.

Additionally, the sUAS in this petition have an autonomous navigation and control system with

GPS guidance along with a high degree of pre-programmed limitations to prevent the potential

for operation outside of the airspace restrictions established. Automated controls enable safe,

reliable operation, as well as advanced networking capabilities. As such, nearly all operations

that would be traditionally handled by a commercial pilot are handled by the intelligent systems

in the aircraft.

Given the fact that there are no occupants or cargo in the aircraft and the fact that the safety

features of the sUAS are highly software controlled and monitored in real-time with a specific

flight management systems, it is proposed that pilot in command should not be required to hold a

commercial pilot certification but rather be able to utilize the privileges of a private pilot

certificate for commercial purposes of operating a sUAS.

Given these conditions and the size, speed, operational capabilities, and lack of combustible fuel,

the risks associated with private pilot operations are diminished such that allowing operations set
forth would meet or exceed the current level of safety.

14 C.F.R. § 91.7 (a): Civil aircraft airworthiness

This regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. Should the exemption be granted allowing commercial operation of the petitioned

sUAS without an airworthiness certificate, no standard will exist for airworthiness of these

aircraft. Given the successful track record of these aircraft combined with the fault monitoring

and other provision previously mentioned herein, an equivalent level of safety will be achieved

by insuring compliance with the manufacturer’s manuals for maintenance, safety, and pre-flight

prior to each flight.

14 CFR § 91.119 (c): Minimum Safe Altitudes: General

This regulation provides that over sparsely populated areas the aircraft cannot be operated closer

than 500 feet to any person, vessel, vehicle, or structure. Because flight operations for purpose of

precision surveys, real estate surveillance and monitoring, structural inspections, and aerial

photography are required to be performed at relatively low altitudes (below 400 feet) an

exemption from Section 91.119(c) is needed. 

The equivalent level of safety will be achieved because these aircraft will only fly over private

property with the permission of the landowner and will not be operated in congested or

populated areas. Despite flying at lower altitudes than more conventional manned aircraft, an

equivalent level of safety will be achieved given the size, weight, speed, and material with which

the aircraft are built. Additionally the aircraft are not designed for transit but rather for limited

flights for a specific purpose. Because of this inherent constraint, it is considered that the

lowered minimum safe altitude will provide an improved or equivalent level of safety compared

to large aircraft with pilot, passenger, flammable fuel, and cargo transitioning across many miles

to perform its duties.

14 CFR 91.121 – Altimeter settings

This section requires that 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 below 18,000 feet MSL to:

• The current reported altimeter setting of a station along the route and within 100 nautical miles

of the aircraft;

• If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current

reported altimeter setting of an appropriate available station;

• 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.

Due to the very limited area of operation afforded by line of sight operation and the low altitudes

with which these operations are targeted, the intent of this section does not affect the level of

safety for sUAS operations. To provide an equivalent level of safety, ground level reference

altitudes are established in part by onboard GPS during the pre-flight tests.

14 C.F.R. § 91.151 (a) (1): Fuel Requirements for Flight in VFR Conditions

The regulation provides that no person may begin a flight in an airplane under day-VFR

conditions unless there is enough fuel to fly to the first point of intended landing and to fly after
that for at least 30 minutes. Given that the flights of the proposed aircraft are much shorter in

duration (less than 40 minutes), have a limited area of operation, and limited size, weight, and

speed, an equivalent level of safety is achieved through built in battery power monitoring

provisions and the Operating Conditions outline in this petition. Those conditions coupled with

the built in low battery “return to home” features and fail safe checks built into the aircraft will

provide an equivalent level of safety.

14 C.F.R. § 91.405 (a): Maintenance Required

Maintenance of the petitioned sUAS is performed by the operator in accordance with the

instruction materials provided by the manufacturer and as provided during training as applicable.

An equivalent level of safety can be achieved in lieu of the current rule when these instructions

and training are followed and because the inherent properties of the aircraft which include:

- Small size and mechanical simplicity due to small electronic motors controlled by highly

refined electronic circuits as compared to conventional aircraft with large fuel propelled

engines controlled by a complex series of mechanical systems and linkages requiring a

high level of skill by the maintenance crew.

- Lack of cargo, crew, or passengers.

- Very limited area of remote operation dictated by line of sight.

As provided in the manuals and the operating conditions outlined in this exemption, the operator

will ensure that the sUAS is in working order prior to initiating flight, perform required

maintenance, and keep a log of any maintenance that is performed. It is also recognized that the

trained operator is the person most familiar with the aircraft and is best suited to maintain the

aircraft in an airworthy condition and to ensure and equivalent level of safety. Key elements of

the aircraft are designed to be easily changed (i.e. propellers) by trained operators such that the

aircraft is easily kept in an airworthy state.

14 CFR § 91.407 (a) (1): Operation after Maintenance, Preventive Maintenance,

Rebuilding or Altercations

This section applies only to aircraft with an airworthiness certificate, therefore these sections

would need exemption. The maintenance, preventative maintenance, rebuilding, and alterations

will be performed by the operator pursuant to the manufacturer’s recommendations and the

operating conditions outlined in this petition. The aircraft will be discrepancy free prior to

initiating flight and will be grounded if mechanical issues are discovered. The operator will

consult with the manufacture regarding any unresolved discrepancies until they have been

restored back to factory standards. Additionally, the simplicity of the aircraft by design

facilitates limited wear parts and ability for basic field maintenance. These aircraft attributes and

procedures will provide an equivalent level of safety.

14 CFR § 91.409 (a) (1) & (2): Inspections

This section applies only to aircraft with an airworthiness certificate, therefore these sections

would need exemption. Pre-flight and post-flight inspections will be accomplished by the

operator to the manufacturer’s recommendations and as outlined in the operating conditions.

Any discrepancies discovered during inspections will be resolved before further flight. An

equivalent level of safety is achieved because of these inspections and the limitations of the

aircraft and flight which include: flights under 400 feet, small size, limited area of operation, and

lack of cargo, crew, or passengers.
14 CFR § 91.417 (a) & (b): Maintenance Records

This section applies only to aircraft with an airworthiness certificate and therefore these sections

would need exemption. Maintenance will be accomplished by the operator pursuant to the

manufacturer’s recommendations and the operating conditions outlined in this petition. The

operator will maintain records of maintenance performed. An equivalent level of safety will be

achieved through the inspection and maintenance outlined above and by the records of

maintenance and repair that will be kept as outlined in this section.