UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF: ALTAVIAN, INC. FOR AN EXEMPTION SEEKING RELIEF FROM THE REQU IREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 14 C.F.R 91.151(a)(1), 91.405(a), 91.407(a)( 1), 91.409(a)(1) & (a)(2), AND

91.417(a) & (b) CONCERNING OPERATION OF THE NOVA F6500 UNMANNED AIRCRAFT SYSTEM PURSUAN T TO SECTION 333 OF THE F A A MODERNIZATION AND REFORM ACT OF 2012 ( PUBLIC LAW 112

- 95)

Submitted on November 18
, 2014

G REGORY S

. W INTON , E SQ

. J ARED M. A LLEN , E SQ

. T HE A VIATION L AW F IRM 1997 Annapolis Exchange Parkway Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 Fax: (866) 568

- 9886 Attorneys for Petitioner2 TABLE OF CONTENTS
Page

GLOSSARY OF ABBREVIATIONS

................................ ................................ ................. 3

SUMMARY

................................ ................................ ................................ ......................... 4

INTRODUCTION AND INTERESTS OF PETITIONER

................................ ................. 4

BACKGROUND

................................ ................................ ................................ ................. 5

BASIS FOR PETITION

................................ ................................ ................................ ...... 6

NAME AND ADDRESS OF PETITIONER

................................ ................................ . 7

THE S PECIFIC SECTIONS OF 14 C.F.R. FROM WHICH ALTAVIAN , INC. SEEKS EXEMPTION

................................ ................................ ................................ ... 8

THE EXTENT OF RELIEF ALTAVIAN , INC. SEEKS AND THE REASON ALTAVIAN , INC. SEEKS THE RELIEF

................................ ................................ .. 1 0

THE REASONS WHY GRANTING ALTAVIAN
, INC. 'S REQUEST WOULD BE IN THE PUBLIC INTEREST

................................ ................................ ..................... 1 1

THE R EASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

................................ ................................ .............. 1 5

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER

.......... 3 1

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT ALTAVIAN , INC. 'S REQUEST

................................ ........................ 3 2

CONCLUSION

................................ ................................ ................................ ................. 3 23 GL OSSARY OF ABBREVIATIONS

AGL Above Ground Level

ATC Air Traffic Control

AV Aerial Vehicle

COA Certificate of Authorization

FAA Federal Aviation Ad ministration

FAR Federal Aviation Regulation

FDEP Florida Department of Environmental Protection

GCS Ground Control Station

NAS National Airspace System

PIC Pilot I n Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VMC Visual Meteorological Conditions4 SUMM ARY

Altavian , Inc

. seeks exemption from the requirements of 14 C.F.R §§ 91.151(a)(1),

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) , to operate an Unmanned
Aircraft System pursuant to Section 333 of the FAA Modernization and Reform A ct of 2012

.
This exem ption will permit Altavian , Inc. to operate an Unmanned Aircraft System (UA S ) for
the purpose of conducting aerial acquisitions and research over the New River Regional Land

Fill located in Union County , Florida.

INTRODUCTION AND IN TERESTS OF THE PETITIONER

Altavian , Inc. (hereinafter referred to as “ Altavian ”) is an unmanned aircraft solutions
provider that integrates engineering and manufacturing with services that enable the technology

for federal, state, local, and commercial c lients. Altavian is focused on providing solutions for
utilizing unmanned aircraft to safely and efficiently collect data that is precise, accurate, and
timely.

Altavian’s mission is to use unmanned aircraft to simplify and increase the effe ctiveness

o f data collection in: Natural Resources and Conservation
, Construction and Infrastructure
, Precision Agriculture
, as well as Inspection and Monitoring

. As set forth in this Petition, Altavian seeks to operate its Nova F6500 UAS over the New
River Regional Landfill located near Raiford 1 i n Union County, Florida. Specifically, t he Nova

F6500 UAS will be used to collect topographic data that is critical to conducting capacity

calculations
, estimating the remaining life of the landfill
, and ensuring complianc e with the
regulations set forth by the Florida Department of Environmental Protection (FDEP)

.

1 Raiford is a town in Union County
, Florida
, United States . The population was 187 at the 2000 census. As of 2004, the population recorded by the U.S. Census Bureau is 193.5 BACKGROUND
Unmanned Aircraft System: Altavian Nova F6500 UAS

Altavian seeks an exemption to operate the Altavian Nova F6500 UAS (also known as

the Nova Block III UAS )
, Serial No. 3016, registration number N 6682B 2

, for compensation or

hire within the n ational a irspace s ystem (“NAS”)

. The Nova F6500 UAS is comprised of an
amphibious unmanned aircraft (UA) and a transportable ground control station. The Nova

F6500 UA has a maximum gross weight of approximately fifteen (15) pounds , while having a
wingspan of 108 inches and a length of 65 inches . The Nova F65 00 UA is equipped with a
single propeller driven by a Lithium Polymer battery powered electric motor.

Fig ure 1 : T he Nova F6500 UA

.

2 A copy of the FAA Registry information for Altavian’s Nova F6500 UAS, registration number N6682B , is attached hereto as Exhibit A, which is submitted with exhibits containing proprietary information, to be held in a separate file pu rsuant to 14 C.F.R. § 11.35(b).6 Proven Operational History of the Nova F6500 UAS in the NAS

The Nova F6500 UAS (also known as the Nova Block III ) is currently operating safely

with in the NAS pursuant to a pproximately fifteen ( 1 5 ) Certificates of Authorization (“COA”)

gra nted by the Federal Aviation Administration (“ FAA ”) to the Middle Tennessee State
University ; Sinclair Community College in Dayton, Ohio ; the U

. S

. Army Corps of Engineers

( Jacksonville District and Mobile District ) ; Mississippi State University for the Pearl River

Basin ; and the University of Florida . The U.S. Army Corp s of Engineers will be operating the

Nova F6500 UAS pursuant to additional COA s in the foreseeable future
, pending approval by

the FAA

.
BASIS FOR PETITION

Petitioner, Altavian , Inc., by and through undersigned counsel, pursuant to the provisions

of t he Federal Aviation Regulations ( 14 C.F.R. § 11.61) and the FAA Modernization and Reform

Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby
petiti ons the Administrator to operate the Nova F6500 UAS in the national airspace system
, and
for an exemption from the requirements of 14 C.F.R §§ 91.151(a)(1)
, 91.405(a), 91.407(a)(1),

91.409(a)(1) & (a)(2), and 91.417(a) & (b )

.

I n consideration of the size, weight, speed, and limited operating area associated with the
unmanned aircraft and its operation, Altavian’s operation of the Nova F6500 UAS meets the

conditions of Section 333 and will not require an airworthiness certificate in accordance with 14

C.F.R . P art 21, Subpart H.
Therefore, Altavian requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &

(a)(2), 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply

to aircraft with an airworthiness certific ate.7

Altavian submits that the requested relief is proper since a n equivalent level of safety will

be ensured

. Altavian, as the manufacturer of the Nova F6500 UAS, will use its technicians to
perform maintenance, alteration s , or preventive maintenance on the unmanned aircraft system
using the methods, techniques, and practices prescribed in the manufacturer’s maintenance

manual . Furthermore, Altavian will document and maintain all maintenance records for the

Nova F6500 UAS.

Altavian also seeks an ex emption from the requirements of Section 91.151(a)(1)
, Fuel
requirements for flight in VFR conditions

. Altavian submits that safety will not be affected by
terminating flights of the battery powered Nova F6500 UA after 90 minutes of continuous
operation o r with 20% remaining batter y power (whichever occurs first )

. In accordance with 14 C.F.R. § 11.81, Altavian provides the following information in
support of its petition for exemption :

A. Name A nd Address Of T he Petitioner.

The name and address of the P etitioner is:

Altavian , Inc. 1724 NE 2nd Street Gainesville, F lorida 32609
The point of contact for this P etition and specific contact information is as follows:
Gregory S. Winton, Esq. The Aviation Law Firm 1997 Annapolis Exchange Parkway
, Suite 3 00 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 | Fax: (866) 568

- 9886 Ema il: Greg@aviationlawexperts.com8

B. The Specific Sections Of 14 C.F.R. From Which Altavian Seeks Exemption.

1. Altavian Se eks Exemption From The Requirements Of Section 91.151 (a)(1)

.
Section 91.151
, entitled Fuel requirements for flight in VFR conditions
, subsection (a)(1),

state s the following:
(a) No person may begin a flight in an airplane under VFR conditions unless (co nsidering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

-- (1) During the day, to fly after that for at least 30 minutes [.]

2

. Altavian Seeks Exemption F rom T he R equirement O f Section 91.405(a)

.
Section 91. 405
, entitled Maintenance required
, subsection ( a )
, states the follow ing :
Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall be tween required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter [.]

3

. Altavian Seeks Exemption F rom The Requirements Of Section 91.407(a)(1)

.
Section 91. 407
, entitled Operation after maintenance, preventive mainte nance,
rebuilding, or alteration , subsection (a)(1)
, state s the following:
(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

--
(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter [.]

4

. Altavian Seeks Exemption F rom The Requirements Of Sections 91.409(a)(1) and 91.409( a)(2 ).

Section 91.409
, entitled Inspections , subsection (a)
, state s the following:
(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been appr oved for return to service by a person authorized by § 43.7 of this chapter; or9

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

5

. Altavian Seeks Exemption From The Requirements Of Section s 9 1.417(a) and 91.417 (b)

.
Section 91.417
, entitled Maintenance records , subsections (a) and (b), state the
following:
(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each airc raft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completion of t he work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for return to service.
(2) Records containing the following information:
(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time bas is.
(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.
(v) The current status of applicable airworthiness directi ves (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.10

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.
(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.
(2) The records specified in paragraph (a)(2) of this section shall be retained a nd transferred with the aircraft at the time the aircraft is sold.
(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C

. The Extent Of Relief Altavian Seeks And The R eason Altavian Seeks The Relief

.
1. Extent of Relief Altavian Seeks And The Reason Altavian Seeks Relief From Section 91.151(a) (1)

.

R elief from Section 91.151(a)(1) is requested to the exte nt required to allow flights of the
battery powered Nova F6500 UA during daylight hours in visual flight rules ( VFR ) conditions to

continue for a total duration of 90 minutes
, or until 20% battery power is remaining (whichever

occurs first )

. Altavian see ks the requested relief because without an exemption from Section

91.151(a)(1), the flight time duration of the battery power ed Nova F6500 UA will be reduced by

one third, which would severely constrain the practicality of any aerial acquisition and resear ch
operations that Altavian propose s to conduct pursuant to this Petition.
Significantly, as set forth below, the technical specifications of the Nova F6500 UAS, the
Nova Operat ions Manual, and Altavian’s proposed operating limitations
, ensure that Altav ian

will safely operate the battery powered Nova F6500 UA during daylight hours in VFR conditions
for a total duration of 90 minutes, or until 20% battery power is remaining (whichever occurs

first )

.11

2. Extent of Relief Altavian Seeks And The Reason Al tavian Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only
apply to aircraft wit h an airworthiness certificate, Altavia n requests relief from these Sections

because the Nova F6500 UAS does not require an airworthiness certificate. A s set forth more
fully below, the Nova F6500 UAS meets the conditions of Section 333 for operation without an

airworthiness certificate

. Acco rdingly, Altavian, which manufactures the Nova F6500 UAS, will
use Altavian technicians to perform maintenance, alteration s , or preventive maintenance on the
unmanned aircraft system using the methods, techniques, and practices prescribed in the

manufactur er’s maintenance manual

. Furthermore, Altavian w ill document and maintain all

maintenance records for the Nova F6500 UAS.

D

. The Reasons Why Granting Altavian ’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As a Wh ole

.
Gr anting the present Petition will further the public interest by allowing Altavian to
safely, efficiently, and economically perform aerial acquisition s and research over the New River
Regional Land Fill located near Raiford in Union County, Florida

. As set forth below, t he Nova

F6500 UAS will be used to collect critical data about the bioreactor landfill, which is the first of

its kind in Florida

. Additionally, use of the Nova F6500 UAS will decrease congestion of the
NAS, reduce pollution, and pr ovide significant benefits to the economy. Notably, the benefits of
the proposed operation of the Nova F6500 UAS will be realized without implicating any privacy

issues.

1. The Public Will Benefit From The Aerial Acquisition And Research Performe d.

Altavian submits this Petition to perform aerial acquisition s and research in support of the
New River Regional bioreactor landfill , which accelerates waste decomposition . T he New River12

Regional Landfill is the first of its kind in the s tate of Flori da . Pursuant to this Petition
, t he Nova

F6500 UAS will be used to collect topographic data about the landfill that will be critical in
conducting capacity calculations, estimating the remaining life of the landfill, and ensuring
compliance with the regula tions set forth by the Florida Department of Environmental Protection

(FDEP).
The New River Regional Landfill not only serves the citizens of Baker, Bradford
, and

Union Counties in Florida ; it is the first bioreactor landfill in the state of Florida, and will
provide valuable research data that will benefit the entire field of waste management. By
introducing air and water into solid waste, t he New River Regional Landfill is a bioreactor

landfill that accelerates the waste decomposition process, which ext end s the life of the landfill
and also generates methane gas that may be captured as an alternative energy source. Data
collected from the New River Regional Landfill will provide landfill operators and engineers a

valuable tool in the d esign of landfills

. By operating the Nova F6500 UAS , Altavian will be able to perform safe, efficient, and
economical aerial acquisition s that will directly benefit the public. Specifically, the Nova F6500

UAS will be used to collect topographic data about the landfill th at will be critical in conducting
capacity calculations, estimating the remaining life of the landfill, and ensuring compliance with

the regulations set forth by the Florida Department of Environmental Protection (FDEP). For
example, FDEP R ule 62

- 701.500( 13)(c), F.A.C, requires all landfills to submit an annual
estimate of the remaining life and capacity of the permitted landfill area

. Currently, a erial
surveying by manned aircraft is often the method utilized to collect the topographic data used to
perfo rm the capacity calculations. Furthermore, the topographic data collected annually by aerial13

surveying is utilized in estimating the remaining life of the landfill
, which is used in calculating

financial assurance as required by FDEP R ule 62

- 701.630, F.A. C.

2. The Public Will Benefit From Decreased Congestion Of The NAS.

The Nova F6500 UA is battery powered and serves as a safe, efficient, and economical
alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the
amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use

of a Nova F6500 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and
air pollution, as well as increase the safety of life and property in the air and on the ground.
Furthermore, by reducing the number of manned aircraft operating in the NAS,
congestion around airports caused by arriving and departing aircraft will be reduced. The Nova

F6500 UA does not require an airport to takeoff or l and. Likewise, a reduction of manned
aircraft conducting aerial survey missions would result in fewer aircraft that must be handled by
air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight
operations.

3

. The P ublic Will Benefit From The Safety And Efficiency Of The Nova F6500 UAS.
Conducting aerial acquisitions with the Nova F6500 UAS
, instead of manned aircraft
, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated
during traditional aerial survey flight operations. By using battery power and an electric motor, the

Nova F6500 UA S produces no air pollution, and is the most viable environmentally conscious
alternative to the cabin class, six cylinder intern al combustion twin engine aircraft that are
typically utilized for aerial acquisitions, while burning approximately 20

- 30 gallons per hour of

leaded aviation fuel. The Nova F6500 UA, while reducing the carbon footprint of aerial
acquisitions , also elimina tes noise pollution
, as its battery powered electric motor is barely audible14

during the take

- off phase, and cannot be heard when operating more than 100 feet above ground

level.
By using the Nova F6500 UAS to perform aerial acquisitions, the substanti al risk to life
and property in the air and on the ground , which is usually associated with traditional manned
aircraft flight operations
, will be substantially reduced or completely eliminated

. Aside from the

lack of aircrew members located onboard the a ircraft, the Nova F6500 UA (weighing
approximately fifteen (15) pounds at its maximum gross weight with a wingspan of 108 inches and
a length of 65 inches, with no fuel on board)
, has less physical potential for collateral damage to
life and property on th e ground
, and in the air
, compared to the manned aircraft that typically

conduct aerial acquisitions (weighing approximately 6,500 pounds with a wingspan of

appr oximately 40 feet, a length of 3 4 feet, and a fuel capacity of 180 gallons).

4

. Performing Ae rial Acquisition Operations With The Nova F6500 UAS Will Benefit The Economy.
In addition to being safe and efficient, the Nova F6500 UAS is also an economical
alternative to using manned aircraft to conduct aerial acquisitions . As such, operation of the

Nova F6500 UAS will allow United States based companies , like Altavian
, to remain

co mpetitive and contribute to growth of the U .S. economy. Specifically, with the rising cost of

aviation fuel and the Environmental Protection Agency (“ EPA ”) regulato ry actions phasing out
leaded fuels, U.S. owned and operated companies must adopt new and alternative technology in
order to remain competitive. Operating the battery powered Nova F6500 UA S is one such
technology that not only allows companies greater ope rational flexibility compared to manned
aircraft, but provides such flexibility without the high operational cost of a traditional manned

aircraft.15

By operating the Nova F6500 UAS , companies such as Altavian can remain competitive
and profitable, and the refore provide greater job stability to employees and contractors, which
will ultimately contribute to growth of the U.S. economy. Improved financial performance of
U.S. companies
, through commercial use of the Nova F6500 UAS
, provides a stable workforce
that increases consumer spending; improves local, state, and federal tax revenues; and allows
companies to invest in research and development in order to remain competitive both in the

United States and abroad.

5

. There Are No Privacy Issues

.
Like the man ned aerial acquisition flight operations that have been conducted for

d ecades
, the proposed operation of the Nova F6500 UAS will not implicate any privacy issues.
Specifically, the Nova F6500 UAS will be operated only in rural areas, and in accordance wit h

all Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. §

91.119. Most significantly
, the Nova F6500 UAS will not be operated closer than 500 feet to
any person, vessel, vehicle, or structure , except when necessary fo r takeoff or landing.

E

. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which Altavian Seeks Exemption.
1. Reasons Why The Nova F6 500 UAS Meets The Conditions Of The FAA Modernizatio n and Reform Act of 2012 (FMRA) Section 333.
In consideration of the size, weight, speed, and limited operating area associated with the
unmanned aircraft and its operation, Altavian’s operation of the Nova F6500 UAS meets the

conditions of FMRA Section 333
, and will not require an airworthiness certificate in accordance
with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for UAS to operate without airworthiness certification and

sets for th requirements for considering whether a UAS will create a hazard to users of the NAS16

or the public
, or otherwise pose a threat to national security. Specifically, FMRA Section 333
states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before com pletion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.
(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and
(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identified under paragraph (1).

(c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely i n the national airspace system, the Secr etary shall establish requirements for the safe ope ration of such aircraft systems in the national airspace system.

I n seeking this exemption, Altavian submits that the Nova F6500 UAS can operate safely

in the NAS pursuant to FMRA Section 333, as demonst rated by : ( a ) the safe operational history

and current use of the Nova F6500 UAS in the NAS ; ( b ) the characteristics of the Nova F6500

UAS ; ( c ) the limited area of Altavian ’s intended operation; ( d ) the private pilot certification
requirement; and ( e ) the specific operating limitations

.

a . T he Nova F6500 UAS Has A Proven History O f Operation In The NAS Pursuant To A Certificate Of Authorization (“COA”).

The Nova F6500 UAS (also known as the Nova Block III) is currently operating safely in

the NAS pursuant to approximately fifteen (1 5 ) Certificates of Authorization (“COA”) granted
by the FAA to the Middle Tennessee State University ; Sinclair Community College in Ohio ; the17

U

. S

. Army Corps of Engineers ( Jacksonville District and Mobile District ); Miss issippi State
University for the Pearl River Basin ; and the University of Florida . The U.S. Army Corps of
Engineers will be operating the Nova F6500 UAS pursua nt to additional COA s in the foreseeable

future
, pending approval by the FAA.

b

. The Specifi cations Of The Nova F6500 UAS Demonstrate Its Safe Characteristics.

The Nova F6500 UAS does not create a hazard to users of the NAS or the public, or
otherwise pose a threat to national security considering its size, weight, speed, or operational

ca pability.

i

. Technical Specifications Of T he Nova F6500 UAS

.

Unmanned Aircraft System The Nova F6500 is an Unmanned Aircraft System that is comprised

of an amphibious unmanned aircraft and a transportable ground station.

Serial No. 3016

Unman ned Aircraft Dimensions Wingspan: 108 in.

Length: 65 in.

Engine (Propulsive Unit) Engine (Propulsive Unit)

(1) Altavian Inc. P/N : 30027 (Electric) FAA Engine Type Cert: None Propulsive Unit Type: 25V, 11 Amp Hour c apacity, Lithium ion batt ery powered, direct drive electric motor

Motor, Electric Sub

- Assembly: Manufacturer: NeuMotor Model: 1509 2.0 HP Peak Power Direct Drive 10 oz. Wt.18 Motor, Controller Sub

- Assembly: Manufacturer: Castle Creation Model: Phoenix Ice 100 Type: Speed Control ler 100 Amps Maximum 4.6 oz. Wt.

Motor, Battery: Manufacturer: MaxAmps, Inc

. Type: Lithium Ion 11 Amp hour 22.2V (nominal)

Fuel Not A pplicable.

NOTE: The Nova F6500 UAS is powered by a Lithium Polymer rechargeable battery, Altavian P/N 30142

.

E ngin e (Propulsive Unit) Limits Maximum Power Output: 2.0 HP

Maximum RPM: 60,000 RPM (reduced to a propeller RPM of 7,200) Maximum Motor Temperature: 170 °F ( 7 7 °C) NOTE : The motor temperature is not displayed to the operator

. Maximum motor, controller su b

- assembly temperature: 194 °F (90 °C) Minimum voltage, motor battery during pre

- flight engine run up after 3 sec

. at max throttle: 22.6V

Propeller and Propeller Limits (1) Altavian Inc

. P/N 30360

FAA Propeller Type Certificate: None Propeller Type: 2

- blade, hinged (folding), carbon fiber reinforced plastic, fixed pitch, tractor
Propeller Sub

- Assembly : Manufacturer: Aeronaut Model: CAM 15x13 Diameter (Nominal): 15 in

.

Battery Command & Control Nova Air Vehicle Battery P / N 30142 powers the motor, and battery

command and control

.19

Airspeed Limits Vne (Never Exceed Speed) 58 knot (30 m/s)

Vno (Maximum Structural Cruising Speed) 48 knots (25 m/s) Va (Maneuvering Speed) 48 knots (25 m/s) Landing Speed: 27 knots (14 m/s)

Empty Weight C.G. Range 20.2

– 21.7 inches aft of datum

Datum Front of Motor Case

Mean Aerodynamic Chord (MAC) 13 in

. long with leading edge 21.2 in

. from nose

Leveling Means Not A pplicable

.

Maximum Weights Ramp 15 lbs

.

Takeoff 15 lbs

. Landing 15 lbs

.

Empty We ight 8.35 lbs.

NOTE : Empty Weight Excludes weight of battery and payload modules

.

Frequencies 902

- 928 MHz (ISM Band)

2.4 GHz (ISM Band)

NOTE : FCC license is not required to utilize the above frequencies; uplink and downlink are on the 900Mhz ban d. If video is utilized, u plink, downlink, and video are all on 2.4 Ghz.

Computer Software Avionics embedded processor
, P/N 3013820

Minimum Crew (1) The Nova F6500 UAS can be operated by a single operator.

Number of Seats (0) Not Applicab le.

Fuel Capacity Not Applicable.

Oil Capacity Not Applicable.

Max. Operating Altitude 1
, 000 ft

. AGL (304 M)

Control Surface Movements Wing Flaps N/A

Aileron Up 30 ° Down 30 °

“V” tail elevator action Up 60° Down 60 °

“V” tail rudder ac tion Up 60° Down 60 °

“V” tail max. combination Rudder elevator action Up 60° Down 60 °

Nominal Endurance 90 minutes above 32 °F (0 °C) 45 minutes below 32 °F (0 °C)

Ambient Outside Air Temperature (OAT) Maximum OAT: 120 ° F (49 ° C) Minim um OAT At Altitude:

- 20 ° F (

- 29 ° C )

Wind Limitation 19 knots

Maintenance This Nova F6500 UAS must be maintained in accordance with the

manufacturer’s m aintenance m anual, or later FAA accepted revision

.21 ii

. The Nova F6500 UAS Autonomous F light A nd Navigation Modes Enable T he UAS To Remain Within A De fined O perational A rea.

A complete description of the au tonomous modes and methods of navigation for the

Nova F6500 UAS is provided in the Nova F6500 UAS Operator Manual at pages 7

- 2 thro ugh 7

-

4 . A copy of the Nova F6500 UAS Operator Manual, which contains proprietary information, is

attached hereto as Exhibit B , and is to be held in a separate file p ursuant to 14 C.F.R. §

11.35(b) 3

.
iii

. The Nova F6500 UAS Is D esigned For Complete Auto nomy F rom Launch To L anding Even In The Unlikely Event Of Loss Of The Control Link Or Navigation.
Although a degradation or loss of the control link
, and / or degradation or loss of the
source of navigation , is unlikely, it is a situation that is well planned for and therefore, is a
benign event . The Nova F6500 UA is designed for complete autonomy from launch to landing

with a line of sight operator in the loop monitoring the airframe.

T he Nova F6500 unmanned aircraft ( UA ) uses a two

- stage fail safe approach for all

avionics failure conditions
, including the event of a loss of communications (“Lost Link”). Upon
loss of the communication signal, the Nova F6500 UA will attempt to reacquire the link. If after

10 seconds the link has not been reacq uired , the Nova F6500 UA will continue to attempt to
reacquire the link while maintaining the current altitude and navigating to the home waypoint,
which is the same as the location of the ground control station. Once at the home way point, the

Nova F6500 UA will loiter while continuing its attempt to reacquire the link for 300 s econds (to
allow for rebooting o f the ground control station, if needed). The Nova F6500 UA will then
continue to attempt to re

- acquire the link while it navigates through the land ing procedure.

3 Exhibits to this Petition contain proprietary information, and in accordance with 14 C.F.R. § 11.35(b), are not to be included in the Federal Docket Manag ement System (FDMS).22

The landing procedure for L os t L ink is identical to a normal landing procedure. The

Nova F6500 UA will descend from “minimum safe altitude” to a breakout altitude (site specific)
while continuing to lo iter around the rally point. Once a t the breakout altitude, the Nova F6500

UA will depart the loiter along a tangential path toward the touchdown spot. The Nova F6500

UA will descend on glide slope from the tangent point to the touchdown spot, slowing down to
flair speed (12m/s) in the fin al moments before touchdown and automatically flare 3 m eters
above the ground.

Loss of GPS signal will result in a two tiered recovery approach. Upon loss of a GPS
signal, the Nova F6500 UA will immediately enter a loiter orbit in an attempt to reacquire a
signal. If after 15 seconds, GPS is not reacquired, the UA will enter tier two. At any time in tier
one or two, the operator can take over with augmented control and utilize its onboard
magnetometer to navigate back to the home waypoint through dead

- r eckoning. During this

failure mode, the observer will call out UA position and movement back to the operator. Once

the UA is close enough to resolve orientation
, or if operating with a live video payload, the
operator can engage manual control and perfor m a manual landing at the pre

- decided landing

site.

If a cascade of failures has occurred and L ost

- L ink has also occurred during tier two
, the

Nova F6500 UA will enter into a loiter

- land procedure; descending in a loiter while reducing
speed until contac t with the ground at flair speed. During this decent, the Nova F6500 UA is still
in controlled flight and at touchdown the forward speed should not exceeded 11 m/s with the
propeller off, minimizing damage to anything that the Nova F6500 UA may c ontact

.
The Nova F6500 UAS Operator Manual at Chapter 9 “Emergency Procedures” fully

describes the features of the Nova F6500 UA and sets forth the unmanned aircraft’s operation in23

the event of a power loss, loss of communications, loss GPS, loss of video link, or sof tware

crash. A copy of Nova F6500 UA S Operator Manual , which contains proprietary information, is

attached hereto as Exhibit B , and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).

iv . The Nova F6500 Ground Control Station And It s Operation.
A complete description of the operation and specifications of the ground control station

( GCS ) and flight control software for the Nova F6500 UAS is provided in the Nova F6500 UAS
Operator Manual at Chapter 2 . A complete overview of the features and operation of the GCS

software is provided at Chapter 7

. A copy of the Nova F6500 UAS Operator Manual, which

contains proprietary information, is attached hereto as Exhibit B , and is to be held in a separate
file pursuant to 14 C.F.R. § 11.35(b)

.

c . F light O perations P ursuant T o T he E xemptio n So ught Would Be L imited T o Areas Over The New River Regional Landfill That Are Not In T he P roximity O f A irports O r Over P opulated A reas.
Pursuant to this Petition, Altavian proposes to only conduct aerial acquisition flight
operations over the New River Regional Land Fill , which is not located near any populated

areas , airports, helipads, or major road way s. Specifically, Altavian ’s proposed area of flight
operations
, the New River Regional Land Fill , is lo cated near Raiford 4

, Union County, Florida,

which is a rural area that is :

1. Not a populated area as depicted on VFR Sectional Aeronautical Charts;

2. N ot within five (5) miles of any airport or helipad ;

3. Not within one hundred (100) meters of state roads having more than two lanes; and

4. Not within fifty (50) meters of state roads having two lanes or less

.

4 Raiford is a town in Union County
, Florida
, United States . The population was 187 at the 2000 census. As of 2004, the population recorded by the U.S. Census Bureau is 193.24

Furthermore
, a ll flight operations will be conducted in accordance with 14 C.F.R. § 91.119,
Minimum safe altitudes: General

.

Figure 2 : Jacksonville (SJAC) V FR Sectional Chart view of Raiford, Florida

.
d

. Flight Operations Of The Nova F6500 UAS Are Limited To The Line Of Sight Of A Certificated Private Pilot i n Command With A Safety Observer.

Altavian will only utilize certificated Private Pilot s who possess a valid Second Class

Airman M edical C ertificate to act as a pilot in command of the Nova F6500 UAS. Additionally,
a safety observer, who will also possess a valid Second Class Airman Medical Certificate, and
who have completed a private pilot gro und school, and passed the FAA private pilot knowledge
test, will assist all pilots . Additionally, both the pilot in command and safety observer must
complete the Altavian Nova Operators Course and meet the experience requirements as set forth

in the Nova Family of Systems Operations Manual

. A copy of the Nova Family of Systems
Operations Manual , which contains propriet ar y information
, is attached hereto as Exhibit C , and
is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b).25 e . Flight s Will B e Conducted Pursuant To S pec ific Operating L imitations.
In seeking this exemption, Altavian proposes to commercially operate the Nova F6500

UAS for the special purpose of conducting aerial acquisitions over the New River Regional

Landf ill
, pursuant to th e following specific operating limitations:

1. Flight operations are permitted only in the defined areas over the New River Regional

Landf ill

.
2. The Nova F6500 UA will be operated at or below 5 00 ft. above ground level ( AGL )
,
except as necessary to comply with the requirements of 14 C.F.R. § 91.119

.
3. T he Nova F6500 UA will be operate d within one mile , and within line of sight
, of the
pilot in command and safety observer.

4. The Nova F6500 UA wi ll be operated pursuant to Day Visual Flight Rules (VFR) in

visual meteor ological conditions (VMC) . The Nova F6500 UAS wi ll be operated
only during daylight hours ( i.e. between the end of morning civil twilight and the
beginning of evening civil twilight, as published in the American Air Almanac,

converted to local time).

5. Flig hts of the Nova F6500 UA wi ll continue for a total duration of 90 minutes, or
until 20% battery power is remaining (whichever occurs first).

6. The Nova F6500 UA wi ll operate from on

- site takeoff/landing location ( s ) directly

next to the pilot in command an d co

- located safety o bserver. If the operation is from a

watercraft, the pilot in command and safety o bserver wi ll remain co

- located on the

same watercraft.26

7. Private pilot certificated airmen, who have completed training, checking, currency,

will conduct operations and recency of experience requirements as approved by the

FAA Administrator.

8. Operation of the Nova F6500 UAS with any inoper ative instruments or equipment

sha ll be prohibited.

9. T he Nova F6500 UAS wi ll be maintained in accordance with the Manufact urer’s

Maintenance Manual.

10. The Nova F6500 UAS wi ll be operated pursuant to 14 C.F.R. P art 91, operating
requirements

.
11. For the proposed flight operation
, only one Nova F6500 UA shall be airborne at any
given time.

12. Prior to flight operations, Altavian wi ll c oordinate and establish two

- way
communications with the nearest Air Traffic Control facility.

13. For any flight operations over U.S. Government or state manage d land s, Altavian wi ll
coordinate with the appropriate authority and ensure that the property owner s have at

least twelve (12) hours of advance notice prior to the proposed flight operations.

C oordination shall include anticipated periods of operation, purpose of the flights,
and contact information for the operator should questions or issues arise.

2. Reasons Why An Exemption From The Requirements Of Section 91.151(a)(1) Would Not Adversely Affect Safety.
A grant of this exemption would ensure the level of safety established by 14C.F.R.

Section 91.151(a)(1) because the technical specifications of th e Nova F6500 UAS, the Nova
Operations Manual, and Altavian’s proposed operating limitations ensure that Altavian may
safely operate the battery powered Nova F6500 UA during daylight hours in VFR conditions for27

a total duration of 90 minutes, or until 20% b attery power is remaining (whichever occurs first).
Furthermore, previous exemptions granted by the FAA concerning Section 91

. 151(a)(1) establish
that safety is not adversely affected when the technical characteristics and operating li mitations

of a UAS a re considered.

T he Nova F6500 UA is powered by a Lithium Ion 11 Amp hour, 22.2V battery, and is
protected by two low battery failsafes , while the ground control station (GCS) provides a b attery

i ndicator on the heads

- up display
, which indicates the Nova F 6500 UA’s current remaining
battery power measured in volts , providing the PIC with constant awareness of the real

- time
battery voltage during a flight.
The two low battery failsafes that protect the Nova F6500 UA are a “Low AV 5 battery”

failsafe and a “ C ritically low AV battery” failsafe. The “ Low AV battery ” fa ilsafe flies the UA

to the location of the ground control station (GCS)
, or identified Rally point
, when the UA
battery reaches a certain threshold of time as configured by the operator ( or 20.4V )

. The

“ Critically low AV battery ” s huts the propulsion motor off and lands the UA at its current
location. This failsafe is triggered if the battery drops below the critical battery voltage as
configured by the operator , or 19.4V

. Furthermore, an e xempti on from th e r equirements o f Section 91.151(a)(1) would not
adversely affect safety because Altavian will only conduct flights during daylight hours in VMC,

with the duration of each flight not to exceed 90 minutes, as set forth by the Nova Family of
System s Operations Manual. A copy of the Nova Family of Systems Operations Manual, which

contains proprietary information, is attached hereto as Exhibit C , and is to be held in a separate
file pursuant to 14 C.F.R. § 11.35(b).

5 The Nova F6500 UAS Operator Manual defines “AV” as “Aerial Vehicle.”28

Likewise, as set forth above, Alt avian has proposed specific operating limitations in this
Petition that will maintain the level of safety established by Section 91.151(a)(1), including the
following : (1) t he Nova F6500 UA will only be operated during daylight hours (i.e. between the

end of morning civil twilight and the beginning of evening civil twilight, as published in the

American Air Almanac, converted to local time) ; (2) Nova F6500 UA will only be operated

pursuant to visual flight r ules (VFR) in visual meteorological conditions (VM C) ; and (3 ) t he
duration of each flight shall not exceed 90 minutes

. Significantly, previous exemptions granted by the FAA concerning Section 91.151(a)(1)
establish that safety is not adversely affected when the technical characteristics and operating

lim itations of the UAS are considered. Relief has been granted for manned aircraft to operate at
less than the minimums prescribed in Section 91.151(a), including Exemption Nos. 2689, 5745,

and 10650. Moreover, the FAA has previously granted relief from Sec tion 91.151(a)(1)
, specific

to UAS
, in circumstances similar, in all material respects, to those presented herein (e.g.
Exemption Nos. 8811, 10808, 10673 , 11042, 11062, 11063, 11064, 11065, 11066, 11067,

11080).

3

. Reasons Why An Exemption From The Requir ements Of Sections 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.
In seeking this exemption, Altavian submits that the level of safety with regard to the
regulatory maintenance a nd alteration requirements established by Sections 91.405(a),

91.407(a)(1), 91.409( a)(1) & (a)(2), 91.417(a) & (b) will be met because Altavian, the

manufacturer of the Nova F6500 UAS, will use its trained technicians to perform maintenance,

alteration s , o r preventive maintenance on the unmanned aircraft system using the methods,29

techniques, and practices prescribed in the manufacturer’s maintenance m anual. Furthermore,

Altavian will document and maintain all maintenance records for the Nova F6500 UAS.

Since the Nova F6500 UAS will be inspected as prescribed by t he manufacturer’s

m aintenance m anual, Altavian will maintain the level of safety established by Section s
91.405(a)
, 91.409(a)(1)
, and 91.409(a)(2)

. The Nova F6500 Maintenance Manual sets forth

S cheduled Maintenance Inspection Procedures for each system and component. I nspection

intervals for the Nova F6500 UAS include preflight and post flight inspections , as well as
scheduled inspections every 25 hours, 50 hours, 75 hours, and 100 hours.

Lik ewise, the exemption sought will not adversely affect safety because Altavian will
perform maintenance, alteration s or preventive maintenance on the unmanned aircraft system
using the methods, techniques, and practices prescribed by t he manufacturer’s m ain tenance

m anual

. The Nova F6500 Maintenance Manual detail s procedures for each component of the
unmanned aircraft, including the c omponents of the p ropulsion system, a vionics system, payload
system, fuselage system, wing, and tail.
A copy of the Nova F6 500 Maintenance Manual, which contains proprietary information,

is attached hereto as Exhibit D , and is to be held in a separate file pursuant to 14 C.F.R. §

11.35(b).

Furthermore, the exemption sought would maintain the level o f safety established by

Sections 91.407, 91.417(a) and 91.417(b) because a ll maintenance o f the Nova F6500 UAS will

be performed by Altavian trained technicians, who will document and maintain maintenance

records for the Nova F6500 UAS. Altavian trained technicians are qualified to conduct any and

all maintenance to ensure the safe operation of the Nova family of UAS , conduct all service
inspections, and authorize the use of each vehicle in the Nova family of UAS based upon30

completion of appropriate inspections. See Nova Family of Systems Operations Manual
, Exhibit

C
, at page 3

- 4

. Pursuant to the Nova Family of Systems Operations Manual and the Nova F6500

Maintenance Manual, a Maintenance Action Form must be completed and saved in the

m aintenance logs for all maintenance that is performed on the UAS. The procedures for
maintaining the maintenance logs for the UAS are fully set forth in the Nova Family of Systems
Oper ations Manual, Exhibit C , at Chapter 5, and the Nova F6500 Maintenance Manual , Exhibit

D , at Chapter 5.
Significa ntly, previous exemptions granted by the FAA concerning Sections 91.405(a),
91.407(a)(1), 91.409(a)(1) & (a)(2), 91.417(a) & (b) establish that safety is not adversely
affected when the technical characteristics and operating limitations of a UAS are consi dered.

T he FAA has previously granted relief specific to UAS in circumstances similar, in all material
respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066,

11067, 11080).

4. T he FAA May Prescribe Any Other Con ditions For Safe Operation.

In accordance with Sec tion 333 of the FAA Modernization and Reform Act of 2012

(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions
, Altavian requests that the FAA
prescribe special conditions for the intended operation of the Nova F6500 UAS , which contain
such safety standards that the Administrator finds necessary to establish a level of safety
equivalent to that established by 14 C.F.R. Part 21, Subpart H
, and 14 C.F.R §§ 91.151(a)(1),

91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), an d 91.417(a) & (b) . Such special conditions will
permit safe operation of the unmanned aircraft for the limited purpose of conducting aerial
acquisitions over the New River Regional Landfill

. FMRA Sec tion 333 sets forth the
requirem ents for considering whether a UAS will create a hazard to users of the NAS or the
public
, or otherwise pose a threat to national security; and further, provides the authority for such31

UAS to operate without airworthiness certification in accordance with any requir ements that
must be established for the safe operation of the aircraft systems in the NAS

.
Likewise , the Administrator may prescribe special conditions pursuant to 14 C.F.R.

§ 21.16
, for operation of the Nova F6500 UAS
, since the airworthiness regulati ons of 14 C.F.R.
Part 21 do not contain adequate o r appropriate safety standards
, due to the novel or unusual
design features of the aircraft . Section 21.16, entitled Special Conditions , states the following:
If the FAA finds that the airworthiness regula tions of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equ ivalent to that established in the regulations.

See 14 C.F.R. § 21.16

. Therefore, in accordance with FMRA Sec tion 333 and 14 C.F.R. § 21.16 , the FAA may
prescribe special conditions for Altavian ’s intended operation of the Nova F6500 UAS , which

contain s uch safety standards that the Administrator finds necessary to establish a level of safety
equivalent to that established by 14 C.F.R. Part 21, Subpart H
, and 14 C.F.R Sections

91.151(a)(1)
, 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & ( b)

.
F. A S ummary That C an Be P ublish ed In T he Federal Register, stating:

The Rules From Which Altavian Seeks Exemption:
Altavian, Inc. seeks exemption from the requirements of 14 C.F.R Sections 91.151(a)(1)
, 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)( 2), and 91.417(a) & (b)

. A Brief Description Of The Nature Of The Exemption Altavian Seeks:
This exemption will permit Altavian , Inc. to operate an Unmanned Aircraft System (UAS) for the purpose of conducting aerial acquisitions and research over the N ew River Regional Land Fill in Union County, Florida.32

G. Any Additional Information, Views, Or Arguments Available To Support Altavian ’s Request.

This Petition is made p ursuant to the FAA Modernization and Reform Act of 2012

(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS
may operate safely in the NAS

. As such
, Altavian ’s request for exemption may be granted
pursuant to the authority of FMRA Sec tion 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Se ction 333 sets forth the require ments for considering whether a UAS will create

a hazard to users of the NAS or the public
, or otherwise pose a threat to national security; and
further, provides the authority for such UAS to operate without airworthiness c ertification.

As discussed in detail above , the Nova F6500 UAS has in the past, and will continue in

the future
, to operate safely in the NAS without creating a hazard to users of the NAS
, or the
public
, or otherwise pose a threat to national security

.
CONCLUSION

As set forth herein
, Altavian seeks an exemption pursuant to 14 C.F.R. § 11.61 and

Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA)
, which will permit safe
operation of the Nova F6500 UAS commercially
, without an airworthiness certificate
, for the

limited purpose of conducting aerial acquisitions over the New River Regional Landfill

. By
granting this Petition, the FAA Administrator will be fulfill ing the Congressional mandate of the

FAA Modernization and Reform Act of 2012, wh ile also advancing the interests of the public
, by
allowing Altavian to safely, efficiently, and economically operate the Nova F6500 UAS
commercially with in the NAS

.
WHEREFORE , in accordance with the Federal Aviation Regulations and the FAA

Modernization and Reform Act of 2012, Section 333, Altavian respectfully requests that the
Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections33

91.151(a)(1)
, 91.405(a), 91.407(a)(1), 91.409(a)(1 ) & (a)(2), and 91.417(a) & (b)
, an d permit

Altavian to operate the Nova F6500 UAS for the purpose of conducting aerial acquisitions and
research over the New River Regional Land Fill in Union County, Florida

.
Dated: November 18 , 2014 Respectfully submitted,

The Aviation Law Firm

/s/ Gregory S. Winton

____________________________ Gregory S. Winton, Esq. Jared M. Allen, Esq. 1997 Annapolis Exchange Parkway Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 Fax: (866) 568

- 9886 Attorneys for Petitioner

cc: James H. Williams , AFS

- 80 Robert Pappas Dean Griffith, Esq.