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Amazon1 respectfully submits this petition for exemption to facilitate the operations of our Prime Air delivery service using unmanned aircraft systems (UAS) in the United States. Specifically, Amazon seeks an exemption: (1) pursuant to 49 U.S.C. § 44807 to fulfill the requirements in 14 C.F.R. § 135.25 that a civil aircraft operated in air commerce have an airworthiness certificate (Section 44807 Exemption); and (2) from various provisions of 14 C.F.R. Parts 61, 91, and 135 to permit operations under a Part 135 air carrier operating certificate (Part 135 AOC) to be conducted using UAS (Operating Exemption).2

III. Amazon MK27 Model UAS The MK27 is an Amazon-designed fixed-wing aircraft capable of VTOL and wing-borne flight. Amazon formally entered aircraft type certificate program status for the MK27 in 2017 and has been engaged on a weekly basis with the FAA on that effort since its initial filing. The MK27 is able to carry internal payloads of up to five pounds,8 with a round-trip range of up to 15 nautical miles. The MK27’s general specifications and performance characteristics, as well as its subsystems, are described below. Additional details are available in the AFM. 1.2m 8 The maximum payload is calculated based on the MK27’s planned performance envelope.

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A. General Specifications & Performance Characteristics

  • UA Type VTOL hybrid
  • Dimensions – Motor to Motor (VTOL) 1.2 m. (between motor pylons)
  • Dimensions – Wing-Span 2.15 m.
  • Max gross takeoff weight 88 lbs. (including payload)
  • Max payload weight at planned range 5 lbs.
  • Nominal cruise speed 60 kts. IAS
  • Max planned operating altitude 400 ft. AGL
  • Max operating altitude 1,200 ft. AGL
  • Planned Range 15 NM. round trip (with reserve)
  • Temperature -10 to 40 degrees C

B. Subsystems

  • Airframe Structure Combination of carbon fiber composite materials and metal
  • Engine (Propulsive Unit) Electric motors, brushless DC, with electronic controllers
  • Fuel Not applicable
  • Batteries Lithium rechargeable batteries
  • Avionics Distributed modular avionics
  • Communications Dual cellular connectivity; redundant
  • Navigation INS/GNSS navigation system
  • Perception/Environment
  • Sensing Systems
  • Use of onboard sensors for obstacle detection during transit and delivery
    phases of flight

This is an interesting proposal in that Part 107 currently has the air space at or below 400 AGL. Amazon has a total of 4 aircraft designs that have been approved by the FAA as Experimental Aircraft, so this should be interesting, and will the Remote Pilot in Command Certification under Part 107 remain the commercial application requirement or will the FAA impose additional pilot certification.

You can read the full Amazon letter here

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