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 REQUIREMENTS 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 PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95)

Submitted on November 18, 2014

GREGORY S. WINTON, ESQ.

JARED M. ALLEN, ESQ.

THE AVIATION LAW FIRM

1997 Annapolis Exchange Parkway

Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550

Fax: (866) 568-9886

Attorneys for Petitioner
2

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 SPECIFIC 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 ..................................................................10

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

IN THE PUBLIC INTEREST .....................................................................................11

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT 

ADVERSELY AFFECT SAFETY..............................................................................15

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........31

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE 

TO SUPPORT ALTAVIAN, INC.'S REQUEST ........................................................32

CONCLUSION.................................................................................................................32
3

GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

ATC Air Traffic Control

AV Aerial Vehicle 

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FDEP Florida Department of Environmental Protection 

GCS Ground Control Station

NAS National Airspace System

PIC Pilot In 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 Conditions 
4

SUMMARY

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 Act of 2012. 

This exemption will permit Altavian, Inc. to operate an Unmanned Aircraft System (UAS) for 

the purpose of conducting aerial acquisitions and research over the New River Regional Land 

Fill located in Union County, Florida.

INTRODUCTION AND INTERESTS 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 clients. 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 effectiveness 

of 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 Raiford1in Union County, Florida. Specifically, the 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 compliance 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 N6682B2, for compensation or 

hire within the national airspace system (“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 F6500 UA is equipped with a 

single propeller driven by a Lithium Polymer battery powered electric motor.

Figure 1: The 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 pursuant 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 

within the NAS pursuant to approximately fifteen (15) Certificates of Authorization (“COA”)

granted 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 Corps of Engineers will be operating the

Nova F6500 UAS pursuant to additional COAs 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 the 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 

petitions 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).

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

C.F.R. Part 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 certificate. 
7

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

be ensured. Altavian, as the manufacturer of the Nova F6500 UAS, will use its technicians to 

perform maintenance, alterations, 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 exemption 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 or with 20% remaining battery 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 And Address Of The Petitioner.

The name and address of the Petitioner is:

Altavian, Inc.

1724 NE 2nd Street 

Gainesville, Florida 32609

The point of contact for this Petition and specific contact information is as follows:

Gregory S. Winton, Esq.

The Aviation Law Firm

1997 Annapolis Exchange Parkway, Suite 300

Annapolis, Maryland 21401

Tel: (301) 294-8550 | Fax: (866) 568-9886

Email: Greg@aviationlawexperts.com
8

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

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

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

states the following:

(a) No person may begin a flight in an airplane 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--

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

2. Altavian Seeks Exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following:

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall 

between 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 From The Requirements Of Section 91.407(a)(1).

Section 91.407, entitled Operation after maintenance, preventive maintenance, 

rebuilding, or alteration, subsection (a)(1), states 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 From The Requirements Of Sections 91.409(a)(1) 

and 91.409(a)(2).

Section 91.409, entitled Inspections, subsection (a), states 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 

approved for return to service by a person authorized by § 43.7 of this chapter; or
9

(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 Sections 91.417(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 aircraft (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 the 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 basis.

(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 directives (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 and 

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 Reason Altavian Seeks The Relief.

1. Extent of Relief Altavian Seeks And The Reason Altavian Seeks Relief From 

Section 91.151(a)(1).

Relief from Section 91.151(a)(1) is requested to the extent 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 seeks the requested relief because without an exemption from Section 

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

one third, which would severely constrain the practicality of any aerial acquisition and research

operations that Altavian proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the Nova F6500 UAS, the 

Nova Operations Manual, and Altavian’s proposed operating limitations, ensure that Altavian 

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 Altavian 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 with an airworthiness certificate, Altavian requests relief from these Sections 

because the Nova F6500 UAS does not require an airworthiness certificate. As set forth more

fully below, the Nova F6500 UAS meets the conditions of Section 333 for operation without an 

airworthiness certificate. Accordingly, Altavian, which manufactures the Nova F6500 UAS, will 

use Altavian technicians to perform maintenance, alterations, 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. 

D. The Reasons Why Granting Altavian’s Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As a Whole.

Granting the present Petition will further the public interest by allowing Altavian to

safely, efficiently, and economically perform aerial acquisitions and research over the New River 

Regional Land Fill located near Raiford in Union County, Florida. As set forth below, the 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 provide 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 

Performed.

Altavian submits this Petition to perform aerial acquisitions and research in support of the

New River Regional bioreactor landfill, which accelerates waste decomposition. The New River
12

Regional Landfill is the first of its kind in the state of Florida. Pursuant to this Petition, the 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 regulations 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, the New River Regional Landfill is a bioreactor

landfill that accelerates the waste decomposition process, which extends 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 design of landfills.

By operating the Nova F6500 UAS, Altavian will be able to perform safe, efficient, and 

economical aerial acquisitions that will directly benefit the public. Specifically, the 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 regulations set forth by the Florida Department of Environmental Protection (FDEP). For 

example, FDEP Rule 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, aerial 

surveying by manned aircraft is often the method utilized to collect the topographic data used to 

perform the capacity calculations. Furthermore, the topographic data collected annually by aerial 
13

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

financial assurance as required by FDEP Rule 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 land. 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 Public 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 UAS produces no air pollution, and is the most viable environmentally conscious 

alternative to the cabin class, six cylinder internal 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 eliminates noise pollution, as its battery powered electric motor is barely audible 
14

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 substantial 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 aircraft, 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 the ground, and in the air, compared to the manned aircraft that typically 

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

approximately 40 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

4. Performing Aerial 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 

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

aviation fuel and the Environmental Protection Agency (“EPA”) regulatory 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 UAS is one such 

technology that not only allows companies greater operational 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 therefore 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 manned aerial acquisition flight operations that have been conducted for 

decades, 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 with 

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 for 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 F6500 UAS Meets The Conditions Of The FAA 

Modernization 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 forth requirements for considering whether a UAS will create a hazard to users of the NAS 
16

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 completion 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 in the national airspace system, 

the Secretary shall establish requirements for the safe operation of such aircraft systems 

in the national airspace system.

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

in the NAS pursuant to FMRA Section 333, as demonstrated 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. The Nova F6500 UAS Has A Proven History Of 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 (15) Certificates of Authorization (“COA”) granted 

by the FAA to the Middle Tennessee State University; Sinclair Community College in Ohio; the 
17

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 Corps of 

Engineers will be operating the Nova F6500 UAS pursuant to additional COAs in the foreseeable 

future, pending approval by the FAA. 

b. The Specifications 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 

capability. 

i. Technical Specifications Of The 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

Unmanned 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 capacity, Lithium ion 

battery 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 Controller

100 Amps Maximum

4.6 oz. Wt.

Motor, Battery:

Manufacturer: MaxAmps, Inc.

Type: Lithium Ion

11 Amp hour

22.2V (nominal)

Fuel Not Applicable.

NOTE: The Nova F6500 UAS is powered by a Lithium 

Polymer rechargeable battery, Altavian P/N 30142.

Engine (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 (77 °C)

NOTE: The motor temperature is not displayed to the 

operator.

Maximum motor, controller sub-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 Applicable.

Maximum Weights Ramp 15 lbs.

Takeoff 15 lbs.

Landing 15 lbs.

Empty Weight 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 band. If 

video is utilized, uplink, downlink, and video are all on 

2.4 Ghz.

Computer Software Avionics embedded processor, P/N 30138
20

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

Number of Seats (0) Not Applicable.

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 action 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)

Minimum 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 maintenance manual, or later FAA accepted revision.
21

ii. The Nova F6500 UAS Autonomous Flight And Navigation

Modes Enable The UAS To Remain Within A Defined 

Operational Area.

A complete description of the autonomous modes and methods of navigation for the 

Nova F6500 UAS is provided in the Nova F6500 UAS Operator Manual at pages 7-2 through 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 pursuant to 14 C.F.R. § 

11.35(b)3.

iii. The Nova F6500 UAS Is Designed For Complete Autonomy 

From Launch To Landing 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. 

The Nova F6500 unmanned aircraft (UA) uses a two-stage failsafe 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 reacquired, 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 waypoint, the 

Nova F6500 UA will loiter while continuing its attempt to reacquire the link for 300 seconds (to 

allow for rebooting of 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 landing 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 Management System (FDMS).
22

The landing procedure for Lost Link 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 loiter around the rally point. Once at 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 final moments before touchdown and automatically flare 3 meters

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-reckoning. 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 perform a manual landing at the pre-decided landing 

site. 

If a cascade of failures has occurred and Lost-Link 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 contact 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 contact.

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 in 
23

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

crash. A copy of 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).

iv. The Nova F6500 Ground Control Station And Its 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. Flight Operations Pursuant To The Exemption Sought Would Be 

Limited To Areas Over The New River Regional Landfill That Are

Not In The Proximity Of Airports Or Over Populated Areas.

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 roadways. Specifically, Altavian’s proposed area of flight 

operations, the New River Regional Land Fill, is located near Raiford4, Union County, Florida,

which is a rural area that is:

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

2. Not 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, all flight operations will be conducted in accordance with 14 C.F.R. § 91.119, 

Minimum safe altitudes: General.

Figure 2: Jacksonville (SJAC) VFR 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 in Command With 

A Safety Observer.

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

Airman Medical Certificate 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 ground 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 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).
25

e. Flights Will Be Conducted Pursuant To Specific Operating 

Limitations.

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 

Landfill, pursuant to the following specific operating limitations:

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

Landfill.

2. The Nova F6500 UA will be operated at or below 500 ft. above ground level (AGL), 

except as necessary to comply with the requirements of 14 C.F.R. § 91.119.

3. The Nova F6500 UA will be operated within one mile, and within line of sight, of the 

pilot in command and safety observer.

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

visual meteorological conditions (VMC). The Nova F6500 UAS will 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. Flights of the Nova F6500 UA will continue for a total duration of 90 minutes, or 

until 20% battery power is remaining (whichever occurs first). 

6. The Nova F6500 UA will operate from on-site takeoff/landing location(s) directly 

next to the pilot in command and co-located safety observer. If the operation is from a 

watercraft, the pilot in command and safety observer will 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 inoperative instruments or equipment 

shall be prohibited.

9. The Nova F6500 UAS will be maintained in accordance with the Manufacturer’s 

Maintenance Manual.

10. The Nova F6500 UAS will be operated pursuant to 14 C.F.R. Part 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 will coordinate and establish two-way 

communications with the nearest Air Traffic Control facility. 

13. For any flight operations over U.S. Government or state managed lands, Altavian will

coordinate with the appropriate authority and ensure that the property owners have at 

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

Coordination 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 the 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 for 
27

a total duration of 90 minutes, or until 20% battery 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 limitations 

of a UAS are considered.

The 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 battery 

indicator on the heads-up display, which indicates the Nova F6500 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 AV5battery” 

failsafe and a “Critically low AV battery” failsafe. The “Low AV battery” failsafe 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” shuts 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 exemption from the requirements of 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 

Systems 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, Altavian 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) the 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 rules (VFR) in visual meteorological conditions (VMC); and (3) the 

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 

limitations 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 Section 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 Requirements 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 and 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, 

alterations, or preventive maintenance on the unmanned aircraft system using the methods, 
29

techniques, and practices prescribed in the manufacturer’s maintenance manual. 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 the manufacturer’s

maintenance manual, Altavian will maintain the level of safety established by Sections

91.405(a), 91.409(a)(1), and 91.409(a)(2). The Nova F6500 Maintenance Manual sets forth

Scheduled Maintenance Inspection Procedures for each system and component. Inspection 

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. 

Likewise, the exemption sought will not adversely affect safety because Altavian will

perform maintenance, alterations or preventive maintenance on the unmanned aircraft system

using the methods, techniques, and practices prescribed by the manufacturer’s maintenance 

manual. The Nova F6500 Maintenance Manual details procedures for each component of the 

unmanned aircraft, including the components of the propulsion system, avionics system, payload 

system, fuselage system, wing, and tail. 

A copy of the Nova F6500 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 of safety established by 

Sections 91.407, 91.417(a) and 91.417(b) because all maintenance of 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 upon 
30

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 

maintenance 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 

Operations Manual, Exhibit C, at Chapter 5, and the Nova F6500 Maintenance Manual, Exhibit 

D, at Chapter 5.

Significantly, 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 considered. 

The 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. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 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), and 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 Section 333 sets forth the 

requirements 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 
31

UAS to operate without airworthiness certification in accordance with any requirements 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 regulations of 14 C.F.R. 

Part 21 do not contain adequate or 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 regulations 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 equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 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 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 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 Summary That Can Be Published In The 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 New 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 pursuant 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 Section 333 and 14 C.F.R. Part 11, as set forth above. 

FMRA Section 333 sets forth the requirements 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 certification. 

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 fulfilling the Congressional mandate of the 

FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by 

allowing Altavian to safely, efficiently, and economically operate the Nova F6500 UAS

commercially within 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 Sections 
33

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