Reid	Plumbo July 31 st ,	2015
Director	of Product Management
Sentera

, LLC
6636	Cedar	Ave	South Minneapolis,	MN	55423

U.S.	Department	of	Transportation Docket	Management	Sy stem 1200	New	Jersey	Ave.,	SE Washington,	DC	20590

Dear	Sir	or	Madam:

Attached,	please	find	Sentera

, LLC’s requ est	for	an	exemption	from	certain stated	Federal Aviation	Regulations	to	allow	commercial	operation	of	its	small	unmanned	aircraft	systems (hereafter	referred	to	as	“SUAS”	or	“Drone”)	for	the	purpose s	of aerial	phot ography, cinematography,	videogr aphy,	mapping,	crop	surveying, aerial	inspections ,	data	collection, security	monitoring,	public	safety,	first	responder	and	emergency	response	support and other	flight	operations ,	so	long	as	such	operations	are	conducted within	and	under	the conditions	outlined	herein	or	as	may	be	established	by	the	FAA	as	required	by	Section	333
of	the	FAA	Modernization	and	Reform	Act	of	2012

.

Please	be	advised	that	the	FAA	has	previously	issued	grants	of	exemption	in	circumstances
simila r	in	all	material	aspects	to	those	requested	in	this	petition

, notably in Exemption	No s

. 114 87 to	HAZON	Solutions

, 11552	to	Sinclair	Community	College,	and	11110	to	Trimble Navigation	Ltd. for	fixed	wing	SUAS	similar	to	the	fixed	wing	SUAS	proposed	herein, in Exemption	No.	11446	to	Trumbull	Unmanned	LLC	which	includes	the	specific	VTOL	SUAS proposed	herein, Exemption	No.	11925	to	James	Michael	Hourihan	for	VTOL	SUAS

- based emergency	response	support	operations

. Therefore,	Sentera,	LLC	respectfully	requests this exemption	be	considered	under	the	“summary	grant”	process.

As	detailed	in	this	document,	a	granted	exemption	would	permit	the commercial operation of	SUAS	under	controlled	conditions in	airspace	that	is	limited and controlled via subsequent	COA applications .	Predominantly,	Sentera,	LLC	seeks	to	operate	under	the “Blanket 200ft COA”	guidance	that	was	issued	by	the	FAA	in	March	2015	and	respectfully requests	the	“Blanket 200ft COA”	be	granted	in	concert	with	these	exemptions.

The	requested	exemptio ns	and	proposed limitations provide	for	at	least	an	equivalent	or higher	level	of	safety	to	operations	under	the	current	regulatory	structure,	specifically safety	enhancements	to	personnel	climbing vertical	infrastructure	and create	a	low

- risk
alternative to	certain manned	aviation	operations.

As	outlined in	this	request	for	exemption ,	the	SUAS	Sentera

, LLC prop oses	to	use	are: Sentera	Phoenix Lockheed	Martin	Procerus	Technologies (LMPT) Indago

### 2 If	I	can	provide	any	additional	information	in	support	of	your	review	of	this	petition,	please
do	not	hesitate	to	call	me	at 952

- 242

- 9241 or	send	an	email	to	reid.plumbo@sentera.com

.

Sincerely,

/s/
Reid	Plumbo Director	of	Program	Management Sentera,	LL C

### 3 Section	1:	Introduction	&	Interest	of Sentera,	LLC Sentera,	LLC	is	a	developer	of	precision	sensing	solutions	for	the	industrial,	commercial

, agricultural and	first	responder markets. The	staff	and	leadership	at	Sentera,	LLC	offer	over 100	years	of experience	in	the	SUAS	industry	and	have	flown	several

- thousand	flig ht	hours on	various	UAS	systems.	This	team	has	deep	experience	in	SUAS	airspace	integration, airworthiness	and	flight	operations,	including	the	successful	award	of	an	SUAS
airworthiness	ce rtificate	issued	by	the	British	Military.	S entera,	LLC	also	has	on	staff	a professional airman holding	CFI,	CFII	and	MEI	certificates with nearly	3,000hrs	of	flight experience,	including	over	900	hours	of	multi

- engine	flight	instruction.	Sentera,	LLC’s	has the	background	and	team	to safely	integrate	within	the	NAS	and provide	low

- risk,	cost

effective	airborne	data	and	photography	to	its	customers.

Sentera,	LLC	proposes	to	commercially	operate	its Sentera	Phoenix	and Lockheed	Martin Procerus	Technologies	( L MPT ) Indago SUAS	platforms	for	the	purposes	of aerial inspections,	crop	and	agricultural	surveys,	aerial	photography,	videography,	data	collection

, security	monitoring, public	safety,	first	responder	and emergency	response	support and other	flight	operatio ns	conforming	to	the proposed limitations	and	restrictions.	Sentera, LLC	holds	that	commercially	operating	an	SUAS	within	the	NAS	under	the se same limitations	and	restrictions	will	not	pose	a	hazard	to	manned	aircraft,	and	that	operation	of
its	SUAS	is	in the	public	best	interest	by	providing	an	inexpensive,	low

- risk	alternative	to manned	survey	operations.

Section	2:	Regarding	the	Unmanned	Aircraft	System The	FAA’s	public	guidance	on	filing	an	exemption	under	Section	333 is	reprinted	below.
This	section intends	to	fulfill	each	requirement	of	this	guidance.

1.	Petitioners	should	describe	how	the	proposed	UAS	operation	will	be	safely	conducted	to minimize	risk	to	the	NAS	or	to	persons	and	property	on	the	ground.	Specifically,	petitioners
should	describe	th e	design	and	operational	characteristics	for	the	type(s)	of	UAS	they	intend	to operate,	e.g.	aircraft	performance	and	performance	limitations,	operating	procedures,	and aircraft	loading	information	in	as	much	detail	as	possible.	This	could	be	provided	in	t he petition	or	in	an	Aircraft	Flight	Manual	or	similar	document.

NOTE:	The	FAA	will	consider	all	information	and	data	submitted	by	the	petitioner	that describes	the	UAS	developmental	and	operational	history.	This	could	include	statistical	data	or
other	do cumentation	for	the	specific	design	and	performance	characteristics	of	the	UAS, including	the	operational	history	and	operational	failure	modes,	obtained	through	previous Research	&	Development	(R&D)	and/or	flight	test	activities,	e.g.	operations	conducted under	a COA,	with	a	civil	airworthiness	certificate,	or	under	other	authorized	operating	conditions.

2.	Petitioners	should	describe	any	procedures	they	would	implement,	such	as	pre

- flight inspections,	maintenance,	and	repair,	to	ensure	that	the	UAS	is	in a	condition	for	safe	flight. This	could	be	provided	in	the	petition,	an	Aircraft	Flight	Manual,	a	Maintenance	and Inspection	Manual,	or	similar	document.

NOTE:	The	Aircraft	Flight	Manual	and	Maintenance	and	Inspection	Manual	may
be separate	documents	or	combined	in	a	single	document.

3.	The	petitioner	should	describe	the	Radio	Frequency	(RF)	spectrum	used	for	control	of	the UAS	and	associated	equipment	that	is	part	of	the	UAS	(i.e.,	sensors,	cameras,	etc.),	and	whether

### 4 it	complies with	Federal	Communications	Commission	(FCC)	or	other	appropriate	government oversight	agency	requirements.

NOTE:	Petitioners	should	be	able	to	provide	the	FCC	approval	letter	or	show	compliance	with FCC	requirements	upon	request.

Sentera,	LLC	intends	to commercially	operate	SUAS	weighing	less	than	10lbs,	during daylight	hours,	within	visual	line	of	sight	of the	PIC, at	altitudes	less	than	400ft	AGL and	at speeds	less	than 52 mph (depending	on	system,	see	Section	2.1	below) .	As	described	later,
Sentera	PIC s	shall	be	fully	qualified	airmen,	holding	at	least	a	sport	pilot	certificate	and
associated	medical	clearance. The	proposed	SUAS	are	equipped	with	GPS

- enabled autopilots,	capable	of	safe,	steady	autonomous	flight	and	guided	by	the	PIC.	The	proposed
SUAS	a re	commercially	available,	“off	the	shelf”	products	that	have	accumulated innumerable	flight	hours	and	they	have	proven	themselves	low

- risk,	safe	aircraft.	Given	the small	size	and	weight,	low	altitudes,	slow	speeds,	a	qualified	PIC,	a	GPS

- equipped	autopil ot, data

- link	and countless	flight	hours,	Sentera,	LLC	holds	that	commercially	operating	these
SUAS	under	the	limitations	and	restrictions	set	forth	is	a	safe	alternative	to	the	current regulatory	structure	and minimize s risk	to	the	NAS	or	to	persons	and	p roperty	on	the ground

.
2.1	Proposed	SUAS Sentera,	LLC	intends	to	operate the Sentera	Phoenix	family	of	SUAS	along	with	the Lockheed	Martin	Procerus	Technologies	(LMPT)	Indago	family	of	SUAS.		Both	of these	types	of	systems	have	been	proven	to	be	reliable	a nd	effective	SUAS	with	the ability	to carry	payloads such	as	cameras,	sensors	and	other	equipment	necessary	to complete Sentera’s aerial	photography,	cinematography,	videography,	mapping, crop	surveying

, inspection security	monitoring,	public	safety,	first responder	and emergency	response	support tasks. Each	SUAS	is	described	below.

Sentera	Phoenix
The Sentera	Phoenix system	is	comprised	of	a fixed	wing, hand

- launched, propeller	driven unmanned	aircraft	and a	laptop	or	tablet	based	ground control,	respons ible	for	both	vehicle	operation	and	camera	functions,	along
with	a	communications	data

- link	providing	bi

- directional	communications between	the	air	vehicle	and	the	ground	control	station. The	Phoenix	SUAS has	the	ability	to	conduct	hand

- launched	takeoffs, precision	landings	in varied	terrain	and	execute	standard	horizontal	flight	maneuvers. The maximum	gross	weight	of	the	Ph oenix is 3.5	lb ( 1588 g ) ,	and	it	measures 8in (203mm)	tall,	22

- 26in	(559

- 660mm)	long	(depending	on	the	model)	and	has either	a	38in	(9 65mm)	or	48in	(1219mm)	wingspan	(again,	depending	on the	model). Its standard	cruise	speed	is	2 9

- 3 5 mph ( 25

- 30	ktas,	13

- 15m/s ), maximum	horizontal	speed	is 52	mph ( 45	ktas,	23	m/s ) and maximum

ascent and	descent speed s are 800	ft/min	(4.1m/s)	is	400	ft/mi n	(2.0m/s) respectively

. The	Ph oenix is	powered	with	a	Lithium	Ion	battery	and	flies for	approximately 6 0	minutes. D etailed	specifications	are	available	in the Sentera	Phoenix	UAS	Pilot	Operational	Handbook	attached	as Appendix	1

.

The	Sentera	Phoenix	system	has	been	proven	to	be	a	reliable	and	effective system	for	operations	such	as	those	proposed	herein	and	has	previously been	approved	for	similar	uses	by	FAA.		The	Sentera	Phoenix	is	an	evolution of	the	Vireo	UAS,	originally	produc ed	by	UTC	Aerospace	Systems	by	the	team that	now	forms	the	core	engineering	team	of	Sentera.		The	Sentera	Phoenix’s

### 5 immediate	predecessor,	the	Vireo	is	currently	operating	in	numerous	FAA

approved	Public	COAs	as	identified	below:

• 2013

- ESA

- 46	COA	Hyde		(P roponent:	NC	State	University)

• 2013

- ESA

- 65	COA	Butner	(Proponent:	NC	State	University)

• 2013

- ESA

- 69	COA	Caratoke	(Proponent:	NC	State	University)

• 2014

- ESA

- 93	COA	Vernon	James	(Proponent:	NC	State	University)

• 2014

- ESA

- 114	COA	Lake	Wheeler	(Proponent:	NC	Stat e	University)

• 2015

- CSA

- 24

- COA	Springfield	Airpark (Proponent:	Sinclair	Community College)

• 2013

- CSA

- 56	Wilmington	Airpark	(Proponent:	Sinclair	Community College)

Lockheed	Martin	Procerus	Technologies	(LMPT)	Indago
The	In dago system	is	comprised	of	a	four

- r otor Vertical	Takeoff	and	Landing (VTOL) unmanned	aircraft	and ground	control	station

– either	a	handheld controller	or	a	laptop/tablet	based	control	station

– which	is	responsible	for both	vehicle	operation	and	camera	functions,	along	with	a	communication s data

- link	providing	bi

- directional	communications	between	the	air	vehicle and	the	ground	control	station. The	Indago	SUAS	has	the	ability	to	conduct vertical	takeoffs	and	landings,	hover	and	execute	standard	horizontal	flight

maneuvers. The	maximum	gr oss	weight	of	the	In dago is 4.8 5	lb	(2 2 00g)

, and	it	measures 32	x	32	x 9 in	(813 x 813 x 229 mm ) .	The	In dago ’s	maximum
horizontal speed	is	30mph	( 13.4 m/s)

, maximum	ascent	speed	is	800	ft/min ( 4.1 m/s),	and	maximum	descent	speed	is	400	ft/min	( 2.0 m/s). The	In dago is	powered	by	a	Lithium	Ion	batter y and	flies	for	approximately 45 minutes. More	detailed	specifications	are	available	in the Indago	User	Guide	attached as	Appendix 3

.

The	Indago	system	has	been	proven	to	be	a	reliable	and	effective	system	for operations	such	as	those	proposed	herein	and	has	previously	been	approved for	similar	uses	by	FAA	in	the	form	of	numerous	Section	333	Exemptions, such	as	those	outlined	on	page	1	of	the	cover	letter	above.

2.2 Maintenance &	Inspection Sentera,	LLC	shall follow	the	man ufacturer’s	maintenance, over haul

, inspection	and	record

- keeping guidelines	as specified	in the	relevant manufacturer	user	manuals,	attached	as Appendices	1	and 3

. Sentera,	LLC will	conduct	inspections	and	maintenance,	which	shall	be	noted	in	the aircraft’s	logbook	including	total	flight	hours	and	the	nature	of	maintenance performed. Comprehensive	maintenance	will	be performed in	conformance
with	the	manufacturer’s guidelines.

In	advance	of	every	flight	operation,	the	Pilot	In	Command	(PIC)	will thoroughly inspe ct	the	S UAS	to	ensure	it	is	safe	to	fly as	described	in the relevant	manufacturer	user	manuals	and	checklists,	attached	as Appendi ces 2 (Sentera	Phoenix)	and 4 (LMPT	Indago) .	Furthermore,	the	PIC	will	conduct

a	pre

- flight	checklist	as	des cribed	in	the	Operations	Manual .	With	both inspections	completed	and	passed,	the	SUAS	shall	be	deemed	safe	to	fly.

### 6 All	SUAS	proposed	under	this	request	for	exemption	will	be in	compliance with	all	manufacturer	maintenance,	system	and	safety	bulletins.

2. 3 Radio	Communications All	radio	systems	used	in	the	proposed SUAS comply	with	FCC	regulations and	have	earned	FCC	approval.	Sentera,	LLC	shall	operate	the	SUAS	in compliance	with	those	approvals. Certificates	of	compliance	may	be	found	in Operations	manuals	in Appendices	1	and 3.

Section	3:	Regarding	the	Unmanned	Aircraf t	PIC The	FAA’s	public	guidance	on	filing	an	exemption	under	Section	333	is	reprinted	below. This	section	intends	to	fulfill	each	requirement	of	this	guidance.

Regarding	the	Unmanned	Aircraft	PIC

4.	Petitioners	should	describe	the	qualifications	required of	any	PIC(s)	who	will	be	directly responsible	for	the	operation	of	the	UAS,	including	information	such	as:	the	level	of	airman certificate	held;	any	applicable	training	related	to	the	operation;	and	any	minimum	hours	of flight	experience	required	by	the PIC(s),	both	total	flight	time	and	the	time	with	the	particular UAS.	If	the	operation	would	use	visual	observers,	petitioners	should	describe	their	roles	and qualifications.

5.	Petitioners	should	describe	the	medical	standards	and	certification	of	the	PIC (s)	directly responsible	for	the	operation	of	the	UAS.

Sentera,	LLC	PIC s shall	poss ess	a	current	airline	transport,	commercial,	private,	recreational or	sport	pilot	certificate.	The	PIC	shall	also	hold	a	current	FAA	airman	medical	certificate	or
a	valid	U .S.	Driver’s	License.	The	PIC shall also	meet	the	flight	review	requirements	specified

in 14	CFR	§	61.56	in	an	aircraft	in	which	the	PIC	is	rated	on	his	or	her	pilot	certificate.

Prior	to	commercial	operations,	Sentera,	LLC	PICs	shall	have	accumulated	and logged	a minimum	of	25	hours	total	time	as	an	SUAS	pilot.	Flights	for	the	purposes	of	training Sentera,	LLC’s	PICs	and	VOs	(training,	proficiency,	and	experience

- building)	and determining	the	PIC’s	ability	to	safely	operate	the	UAS	in	a	manner	consistent with	how	the UAS	will	be	operated	under	this	exemption

, are	requested	under	the	terms	of	this exemption.	Training	operations	shall	only	be	conducted	during	dedicated	training	sessions. During	training,	proficiency,	and	experience

- building	flights,	all	pers ons	not	essential	for flight	operations	shall	be	considered	nonparticipants,	and	the	PIC	shall	operate	the	UA	with appropriate	distance	from	nonparticipants	in	accordance	with	14	CFR	§	91.119

.

Section	4:	Regarding	the	Operation	of	the	Unmanned	Aircraft
The FAA’s	public	guidance	on	filing	an	exemption	under	Section	333	is	reprinted	below

, along	with	Sentera,	LLC’s	proposal .	This	section	intends	to	fulfill	each	requirement	of	this guidance.

Regarding	the	Operation	of	the	Unmanned	Aircraft
6. Petitioners	should fully	describe	their	intended	UAS	operation(s).	Petitioners	should describe	how	the	proposed	operation(s)	would	not	adversely	affect	safety,	or	how	they would	provide	a	level	of	safety	at	least	equivalent	to	that	provided	by	the	rule	from which	exemption	i s	sought.	Petitioners	should	address	any	plans	to	implement	clearly

### 7 defined	operational	borders	and	procedures	to	ensure	public	safety,	which	includes persons	and	property	both	in	the	air	and	on	the	ground.	This	can	be	described	in	the petition,	in	an	Oper ations	Manual,	or	similar	document.		NOTE:	The	FAA	will	closely examine	the	proposed	operation(s)	with	respect	to	safety	of	flight,	NAS	safety considerations,	and	the	safety	of	the	non

- participating	persons	and	property	during the	operational	period	and	wi thin	the	operational	area.
7. Petitioners	should	specify	the	proposed	maximum	operating	speed	and	altitude,	and describe	minimum	flight	visibility	and	distance	from	clouds	for	their	intended operation(s).	Petitioners	should	describe	potential	hazards	and	sa fety	mitigations associated	with	these	proposed	conditions.	These	issues	can	be	addressed	in	the petition,	an	Operations	Manual,	or	similar	document.

The	SUAS	will	be	operated	during daylight hours,	in	compliance	with	visual	flight	rules,	and flown	within	direct	visual	line	of	sight	of	the	PIC	at	all	times and	never	over	congested	or densely	populated	areas	unless	specifically	authorized	by	the	Air	Traffic	Organization

issued	COA .	The	PIC	shal l	use	human	vision	unaided	by	any	device	other	than	corrective lenses,	as	specified	on	the	PIC’s	FAA

- issued	airman	medical	certificate	or	U.S.	driver’s
license.

The	SUAS	shall	be	operated	at	an	altitude	of	no	more	than	400ft	AGL,	unless	specifically
autho rized	and	operating	under	the	terms	of	the	COA,	at speeds	less	than 23 m/s	( 52 mph). The	SUAS	will	not	be	operated	less	than	500ft	below	or	less	than	2000ft	horizontally	from	a cloud,	or	when	visibility	is	less	than	3	statute	miles.

Prior	to	beginning	a	fli ght,	the	PIC	shall	clearly	establish	the	limits	in	latitude,	longitude	and altitude	AGL	to	ensure	compliance	with	the	COA	under	which	the	SUAS	is	flown	and establish	the	“sterile	area”	for	operations.	If	at	any	time,	this	area	is	breached	by unpredicted	ob stacles	(manned	aircraft	or	otherwise),	the	PIC	shall	abort	the	flight.	Manned aircraft	shall	have	right	of	way	at	all	times.

In	case	of	a	reduced	or	diminished control link,	the	SUAS	will	automatically	return	to	a predetermined	point	within	the	private	or	controlled

- access	property.

The	PIC	shall	not	begin	a	flight	unless	there	is	sufficient	available	power	for	the	SUAS	to complete	the	intended	mission	and	to	operate	f or	at	least	five	minutes	after	that.

By	operating	within	the	limitations	and	guidelines	set	forth	herein,	Sentera,	LLC	shall provide	an	equivalent	level	of	safety	to	operations	under	the	existing	regulatory	structure.

8. Petitioners	should	describe	the	char acteristics	of	the	area	of	intended	operation(s)	and the	associated	potential	hazards,	in	accordance	with	the	statutory	mandate	under Section	333		regarding	proximity	to	populated	areas.	These	issues	can	be	addressed	in the	petition,	an	Operations	Manual, or	similar	document.
9. Petitioners	should	describe	if	they	intend	to	operate	in	the	proximity	of	any	airports,	in accordance	with	the	statutory	mandate	under	Section	333	regarding	proximity	to airports.

All	flight	operations	will	be	conducted	at	least	5 00ft	from	all	nonparticipating	persons, vessels,	vehicles	and	structures	on	private	or	controlled	access	property	with	permission from	the	property	owner/controller	or	authorized	representative.	In	some	cases	due	to mission	requirements,	the	SUAS	will	be	o perated	closer	than	500ft	to	commercial	and industrial	infrastructure	and	facilities.	In	these	instances,	Sentera,	LLC	shall	have	the

### 8 authorization	of	the	property	owner/controller	or	from	an	authorized	representative,	and
the	PIC	shall	have	conducted	a	sa fety	assessment	and	determined	that	it	does	not	present	an undue	hazard.	Permission	from	the	property	owner/controller	or	authorized representative	will	be	obtained	for	each	flight	to	be	conducted.

In	accordance	with	the “Blanket	200ft	COA”	guidance	that was	issued	by	the	FAA	in	March
2015

, f light	operations	will	not	take	place	with in

• 5 nm from	an	airport	having	an	operational	control	tower;	or

• 3 nm from	an	airport	with	a	published	instrument	flight	procedure,	but	not	an operational	tower;	or

• 2 nm from	an airport	without	a	published	instrument	flight	procedure	or	an operational	tower;	or

• 2 nm from	a	heliport	with	a	published	instrument	flight	procedure unless	a	letter	of	agreement	with	that	airport’s	management	is	obtained and/or	otherwise permitted	by	an	Air	Traffic	Organization

- issued	CO A

.

Foreseen	hazards include encroachment	of	manned	aviation	operations	and	non

participants	on	the	ground.	Both	of	these	hazards	are	mitigated	by	choice	of	location	(non

congested	areas) and	strict	limits	on	range	(visual	line	of	sight)	and	altitude	established
herein. Operation	under	these	limits	effectively	mitigates	these	risks.

10. The	UAS	must	be	operated	within	visual	line

- of

- sight	(VLOS),	in	accordance	with	the statutory	mandate	unde r	Section	333(b)(1).	Petitioners	should	describe	how	they intend	to		comply	with	his	mandate.
11. Petitioners	should	describe	any	procedures	they	would	implement	for	conducting	a preflight	safety	risk	assessment	to	determine	that	the	UAS	is	in	a	condition	f or	safe flight	(14	CFR	§	91.7(b))	and	that	the	planned	operation	can	be	completed	safely. These	procedures	can	be	addressed	in	the	petition,	an	Aircraft	Flight	Manual, Operations	Manual,	or	similar	document.

As	described	above, The	SUAS	will	be	operated during daylight hours,	in	compliance	with visual	flight	rules,	and	flown	within	direct	visual	line	of	sight	of	the	PIC	at	all	times

. The	PIC shall	use	human	vision	unaided	by	any	device	other	than	corrective	lenses,	as	specified	on
the	PIC’s	FAA

- issued	ai rman	medical	certificate	or	U.S.	driver’s	license.

In	advance	of	every	flight	operation,	the	Pilot	In	Command	(PIC)	will	thoroughly	inspect	the
SUAS	to	ensure	it	is	safe	t o	fly	as	described	in Appendices 1

- 4 .	Furthermore,	the	PIC	will conduct	a	pre

- flight	checklist	as	described	in Appendix 2 (Sentera	Phoenix) and 4 (LMPT Indago) ,	and	ensure	the	planned	operation	can	be	completed	safely	with	sufficient	battery

reserves (including	wind	and	terrain	limitations)

. With	both	inspections	completed	and passed,	the	S UAS	shall	be	deemed	safe	to	fly.

12. If	petitioners	intend	to	conduct	operations	which	have	existing	requirements	to	notify Flight	Standards	District	Offices	(FSDOs)	prior	to	operations

– such	as	motion	pictur e and	television	filming,	or	pipeline	and	powerline	patrol

– petitioners	should	describe their	intended	coordination	in	this	regard	for	their	proposed	operation(s).

Sentera,	LLC’s	aerial	infrastructure	inspections,	cinematography/videography

, agricultur al operations

, security	monitoring,	public	safety,	first	responder	and	emergency	response support	operations do	not	require	notification	to	FSDOs.

### 9 13. The	FAA	intends	to	require	entities	who obtain	an	exemption	under	this	process	to	also obtain	a	Certificate	of	Waiver	or	Authorization	(COA)	from	the	FAA	Air	Traffic Organization	prior	to	conducting	operation(s)	in	the	NAS.	The	COA	application	is
available	here.

As	stated	previously,	Sentera, LLC	shall	obtain	an	Air	Traffic	Organization

- issued	COA	prior to	conducting	any	operations	under	this	requested	grant	of	exemption.	Sentera,	LLC	seeks primarily	to	operate	under	the	“Blanket	200ft	COA”	guidance	offered	by	the	FAA	in	March, 2015	and	respect fully	requests	that	COA	be	issued	concurrently	with	these	exemptions.	For operations	not	conforming	to	the	“Blanket	200ft	COA”	guidance,	Sentera,	LLC	will	seek separate	and	addi tional	COAs	to	operate	its	SUAS.

Section	5:	Requested	Exemptions

14	C.F.R	Part Summary	of	Regulation Proposed	Action 21,	Subpart	H Airworthiness
Certification I n	consideration	of	the	size,	weight, speed,	and	limited	operating	area
associated	with	the	aircraft	and	its operation,	the FAA has previously	held
that	this	aircraft	meets	th e	conditions	of
Section	333 ,	therefore, requested	relief from	14	CFR	part	21,	and	any	associated noise	certification	and	testing requirements	of	part	36,	is	not

necessary. 45.23(b) Display	of	Marks Sentera ,	LLC SUAS	shall	be	identifie d	by
serial	number and	N

- number,	in markings	as	large	as	practical	given	the small	size	of	the	aircraft.	However,	the	2
inch	minimum	set	forth	in	this	rule	is impractical,	therefore	relief	is	requested. 61.23(a) 61.101(e)(4&5)
61 113(a)	&	(b) 61.133(b) 61.315(a) Certification:	Pilots,	Light
Instructors	and	Ground
Instructors In	previous	petitions	for	exemption,	the
FAA	has	held	that a	PIC	of	an	SUAS holding	at	least	a	Sport	Pilot	certificate and	a	U.S.	Driver’s	License,	or	greater medical	certification, would	not adversely	affect	safe	operations	within
the	NAS or	present	a	hazard	to	people	or structures	on	the	ground.	Relief,	subject to	the	limitations	provided	in	this document,	is	requested. 91.7(a) Civil	Aircraft
Airworthiness PICs	operating	on	behalf	of	Sentera ,	LLC shall	perform	preflight	inspections and
ensure	airworthiness prior	to	flight	as
described	in	this	document ,	manuals and	appropriate	appendices.	Relief	from this	requirement	is	not	necessary. 91.9(b)(2)	&	(c ) Civil	aircraft	flight manual,	marking, and placard	requirements Sentera,	LLC	shall	provide	a current SUAS	Flight	Manual,	and	operational
instruction	material	at	the	location	of
the PIC	and/or	Ground	Station

. The	FAA has	previously	determined	that,	given

### 10 this,	r elief	from	this	requirement	is	not

necessary. 91.103 Preflight	Action Sentera,	LLC	will	perform.	Relief	is	not

necessary. 91.105 Flight	Crewmembers	at
Stations No	human	will	be	aboard	the	SUAS operated	by	Sentera,	LLC,	however,	the FAA	has	held	in	previous	petitions	that
relief	is	not	ne cessary. 91.109(a) Flight	Instruction Sentera,	LLC	will	conduct	flight	training in	accordance	with	the	guidance	and limitations	offered	in	this	document,	as well	as	the	Operations	&	Flight	Manuals attached	as	appendices	to	this
document.	The	FAA	has	held in	previous petitions	that	relief	is	not	necessary.
91.119 Minimum	Safe	Altitudes Request	relief	within	limitations	and restrictions	proposed	herein ,	specifically
in	Section	4.
91.121 Altimeter	Settings Each	of	the	SUAS	Sentera,	LLC	proposes to	operate	measure	altitude	with	both barometric	pressure	sensors	and	GPS. Prior	to	each	flight,	the	barometric
altimeter	will	be	set	to	0ft	AGL	instead	of the	setting	of	the	nearest	reporting
station. Sentera,	LLC	ho lds	that	by counting	altitude	in	AGL,	zeroed	at	the point	of	departure,	will	ensure
conformance	to	the	COA	restrictions under	which	the	SUAS	is	operating.
G iven	the	low	operating	altitudes	of system	and	operating	within	the proposed	restrictions,	relief	is requested.
91.151 Fuel	Requirements	in	VFR
Conditions As	described	in	this	document,	the	SUAS Sentera,	LLC	proposes	to operate	have
total	enduranc e	of	between 45 and 60
minutes.	Sent era,	LLC	will	ensure
missions	are	conducted	with	sufficient

reserve	to	o perate	for	at	least	five
minutes	after	the	intended	mission	is complete. The	short	flight	time	makes the	reserves	specified	in 91.151 impractical	and	therefore	relief	is requested.
91.203 Certifications	Required Sentera ,	LLC	will	place	these	documents

at the	location	of	the	ground	station and/or	with	the	PIC.	The	FAA	has previously	held	that	this	is	sufficient	to provide	an	equivalent	level	of	safety,	and therefore,	relief	is	requested.
91.405 Maintenance	Required Relief	is	requested	within	the limitations

### 11 and	conditions	set	forth	in	Section	2.2	of
this	document.
91.407 Operation	After
Maintenance Relief	is	requested	within	the	limitations
and	conditions	set	forth	in	Section	2.2	of
this	document.
91.409 Inspections Relief	is	requested	within	th e	limitations
and	conditions	set	forth	in	Section	2.2	of
this	document.
91.417 Maintenance	Records Relief	is	requested	within	the	limitations
and	conditions	set	forth	in	Section	2.2	of
this	document.

Section	6:	Public	Interest & Equivalent	Level	of	Safety Though	this	is	addressed	in	pieces	of	this	petition,	a	more	complete	answer	is	provided	in
this	section.

Sentera,	LLC	proposes	certain	14	CFR	exemptions to	allow	commercial	operation	of	its

s mall	unmanned	aircraft	systems for	t he	purposes	of	aerial	photography,	cinematography, videography,	mapping,	crop	surveying,	inspections

, data	collection,	security	monitoring, public	safety,	first	responder	and	emergency	response	support and	other	flight	operations, so	long	as	such operations	are	conducted	within	and	under	the	conditions	outlined	herein

.

Traditional agricultural operations such	as	crop	inspections	and	data	collections under	the

curren t	regulatory	structure	include	the	use	of	manned	aircraft,	which	are	expensive,

in efficient	and	cannot	be	safely	operated	in	close	proximity	to	the	ground.	By	using	Drones to	complete	these	missions	the	public	interest	is	served	by	increasing	safety	to	pilots, passengers	and	non

- participants	on	the	ground.

Traditional	industrial	infra structure	inspection	operations	under	the	current	regulatory structure	are	often	performed	1)	from	the	ground,	where	high	detail	is	impossible	2)	by	a climber	at	great	risk	to	his	or	her	personal	safety,	or	3)	by	a	manned	aircraft	where	flying
close	to	ele vated	infrastructure	is	extremely	dangerous,	and	not	permitted	by	14	CFR
91.119.

Traditional	public	safety,	security	(such	as	facility	perimeter	monitoring),	first	responder, natural	resource	management	and	emergency	response/emergency	management	flight

o perations	under	the	current	regulatory	structure	include	the	use	of	manned	aircraft,	which are	expensive,	inefficient	and	can	pose	significant	risks	to	the	aircrew,	property	and structures	and	persons	on	the	ground	when	being	operated	in	close	proximity	to the ground.	By	using	Drones	to	complete	these	missions	the	public	interest	is	served	by increasing	safety	to	pilots,	passengers	and	non

- participants	on	the	ground	while	increasing availability	and	responsiveness	due	to	the	lower	cost	of	equipment	and	oper ations.

Grant	of	exemption ,	with	the	conditions	and	limitations	set	forth	herein, to	Sentera,	LLC	will provide	for	at	least	an	equivalent	or	better	level	of	safety, r educe	risk	to	life	and	property, thereby	serving	the	public	interest.

### 12 Section	7: Summary	of	Exemption	Request	for	the	Federal	Register
In	accordance	with	14	CFR	11.81	and	Section	333	of	the	FAA	Modernization	and	Reform	Act of	2012,	P.L.	112

- 95,	Sentera,	LLC	seeks	exemption	from	the	requirements	of	14	C.F.R 

### §§ Part 21,	Subpart	H

, 45.23(b )

, 61.23(a)

, 61.101(e)(4&5)

, 61	113(a)	&	(b)

, 61.133(b)

, 61.315(a)

, 91.7(a)

, 91.9(b)(2)	&	(c	)

, 91.103

, 91.105

, 91.109(a)

, 91.119

, 91.121

, 91.151

, 91.203

, 91.405

, 91.407 ,	9 1.409 and 91.417 to	operate	small	unmanned	vehicles	weighing 55lbs	or	less	for	commercial	purposes.

Approval	of	these	exemptions	will	allow	Sentera,	LLC	to	conduct	safe,	commercial	operation of	small	unmanned	aircraft	for	the	purposes	of aerial	photography,	cinematograph y, videography,	mapping,	crop	surveying,	inspections

, data	collection,	security	monitoring, public	safety,	first	responder	and	emergency	response	support and	other	flight	operations

.

Section 8 :	Compliance	with	14	CFR	11.81
14	CFR	11.81a

– Published	on	Cov er	Page. 14	CFR	11.81b

– Please	see	Section	5.
14	CFR	11.81c

– Please	see	Sections	2,	3,	4	and	5.
14	CFR	11.81d

– Please	see	Section	6.
14	CFR	11.81e

– Please	see	Section	6.
14	CFR	11.81f

– Please	see	Section	7. 14	CFR	11.81g

– Please	see	Appendices	1

- 4

. 1 4	CFR	11.81h

– Not	applicable.

Appendix 1 : Sentera	Phoenix	UAS	Pilot	Operational	Handbook

Appendix 2 : Sentera	Phoenix	A1,	Phoenix	M1,	Vireo	Pre

- flight	Checklist

Appendix 3 : Lockheed	Martin	Procerus	Technologies	Indago	User	Guide	v1.1 Lockheed	Martin	considers	these	documents	to	be	proprietary	information	and	prefers	to keep	this	confidential.	To	make	it	avai la ble	for	review,	it	has	been	sent	to 333exemptions@faa.gov w ith	the	comment tracking	number	included	in	the	email.	Please

contact reid.plumbo@sentera.com with	questions	or	concerns.

Appendix 4 : Lockheed	Martin	Procerus	Technologies	Indago	Flight	Checklist Lockheed	Martin	considers	these	documents	to	be	proprietary	information	and	prefers	to keep	this	confidential.	To	make	it	available	for	review,	it	has	been	sent	to 333exemptions@faa.gov with	the	comment	tracking	number. Please	contact reid.plumbo@sentera.com with	questions	or	concerns.