UNITEDSTATESDEPARTMENTOFCOMMERCE NationalOceanicandAtmosphericAdministration OFFICEOFMARINEANDAVIATIONOPERATIONS AircraftOperationsCenter P.O.Box6829 MacDillAFB,Florida33608-0829

February 3, 2015

U.S. Department of Transportation Docket Management System 1200 New JerseyAve, SE Washington, DC 20590

Re: Petition of the National Oceanic andAtmosphericAdministration (NOAA) for exemption to 14 C.F.R. § 91.151(b) for use by Small Rotorcraft UnmannedAerial Systems.

Dear Sir/Madam:

The National Oceanic andAtmosphericAdministration (NOAA), hereby applies for an exemption from 14 C.F.R. § 91.151 (b), to allow for government research operations with small unmanned aerial systems (sUAS), namely the DJI Innovations S1000 octocopter. This request is pursuant to Section 333 of the FAA Modernization andReformAct of 2012 and specifically applied to operations specifiedwithin NOAA's UAS COA ASN # 2015-ESA-47-COA.

NOAA has operated its fleet of sUAS's in the National Airspace System under FAA COAs for over a year. The administration now would like to expand its fleet to smaller, more cost effective UAS's, which consequentlyhave endurance times not in compliance with 14 C.F.R. § 91.151 fuel reserve requirements.

The administration's mission is to conduct field experiments that will provide key observations to validate weather model predictions associatedwith thunderstorm formation. The newer rotor-based system sUAS's provide an inexpensive platform filling a critical missing link between surface and satellite remote sensing tools. Having the ability to implement sUAS's in the vicinity of a developing storm also significantly reduces the risk to human life associatedwith manned aircraft.

NOAA requests an exemption from 14 C.F.R. 

### § 91.151(b)'s fuel requirements for rotorcraft flight inVFR conditions. Section 91.151 states: (b) No personmaybegin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.Here, the batterypowering the DJI Innovations S1000 provides approximately 15 minutes ofpowered flight. To meet the 20 minutes reserve requirement in 14 C.F.R. § 91.151, flights could not be conducted. Given the limitations on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a safetymarginbased on a reserve amount of battery life is needed.

An equivalent level of safetywill be achievedbecause the operations will be conducted on-site without significant transit time by the sUAS. All flights will be terminatedwith no less than 22 volts or approximately 25% reserve batterypower still available. This restrictionwould be more than adequate to return the sUAS safely to the ground and its planned landing zone from anywhere in its limited operating area even in the event of an unexpected occurrence. Operation of the sUAS with less than 20 minutes of reserve fuel does not include the type of risks that Section 91.151(b) was intended to alleviate given the size and speed of the small UAS and the proximity of the flight operation to the landing zone. Moreover, operation will be limitedto line-of-sight range.
With exemption from 14 C.F.R. § 91.151, this sUAS will provide a direct and cost-effective impact on furthering NOAA's, National Weather Service stormprediction capabilities; a great importance to the national public interest.

Should you have any questions or need further informationplease feel free to contact the undersigned.

Very Respectfully,



# /:;2---t/J~· MICHAEL



# ~ARINO Lieutenant, NOAA VTOL UnmannedAerial Systems Officer

NOAA Aircraft Operations Center 7917 Hanger Loop Drive Hanger 5 MacDillAFB, FL 33621-5401 Email: michael.marino@noaa.gov Phone: 813-828-4655