UNITED STATES DEPARTMENT OF COMMERCE 

National Oceanic and Atmospheric Administration 

OFFICE OF MARINE AND AVIATION OPERATIONS 

Aircraft Operations Center 

P.O. Box 6829 

MacDill AFB, Florida 33608-0829 

February 3, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave, SE 

Washington, DC 20590 

Re: Petition of the National Oceanic and Atmospheric Administration 

(NOAA) for exemption to 14 C.F.R. § 91.151(b) for use by Small 

Rotorcraft Unmanned Aerial Systems. 

Dear Sir/Madam: 

The National Oceanic and Atmospheric Administration (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 and Reform Act of 

2012 and specifically applied to operations specified within 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 

consequently have 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 

associated with 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 associated with 

manned aircraft. 

NOAA requests an exemption from 14 C.F.R. § 91.151(b) 's fuel 

requirements for rotorcraft flight in VFR conditions. Section 91.151 

states: 

(b) No person may begin 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 battery powering the DJI Innovations S1000 provides 

approximately 15 minutes of powered 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 safety margin based on a reserve amount of battery life is 

needed. 

An equivalent level of safety will be achieved because the operations 

will be conducted on-site without significant transit time by the 

sUAS. All flights will be terminated with no less than 22 volts or 

approximately 25% reserve battery power still available. This 

restriction would 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 limited to 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 storm prediction capabilities; a great importance to 

the national public interest. 

Should you have any questions or need further information please feel 

free to contact the undersigned. 

Very Respectfully, 

/:;2---t/J~· MICHAEL ~ARINO Lieutenant, NOAA 

VTOL Unmanned Aerial Systems Officer 

NOAA Aircraft Operations Center 

7917 Hanger Loop Drive 

Hanger 5 

MacDill AFB, FL 33621-5401 

Email: michael.marino@noaa.gov 

Phone: 813-828-4655