Transportation Docket Management system 1200 New Jersey Ave., SE

W ashington, DC 20590

Re: Exemption Request section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations from 14 CFR 61.113 (a) & (b); 91.103(b); 91.119; 91.121;

91.15 1(a); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) &(b).

Dear Sir or Madam:

Pursuant to section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 CFR Part 11, IRQ Technical Labs LLC hereby applies for an exemption

from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its small unmanned Aircraft systems ("sUAS") for aerial imaging for safety and monitoring sites, so long the conditions as required by

of secured and controlled environment c onstruction as such operations are conducted within and under outlined herein or as may be established by the FAA section 333.

IRQ Technical Labs will perform many different airborne solutions such as: mapping data, sensing, construction, photography, rea l estate, agricultural, environmental, inspections, and FAA certifications. These techniques and procedures and often require our employees to be put in situations that require IRQ Technical Labs to accept risk. we have found that by using a small unmanned aircraft system "sUAS" with a high resolution camera mounted on it, often times we can accomplish the same inspection and alleviate the need to put our employees and public in danger.

IRQ Technical Labs shares congress's goal of getting sUAS flying comme rcially in the united states safely and soon. In the FAA Modernization and Reform Act of 2012, congress directed the FAA "to safely accelerate the integration of civil unmanned aircraft systems into the national airspace system" and, under Section 333 of t hat law, gave the FAA power to grant innovators "expedited operational authorization" to do so. By this petition, IRQ Technical Labs is seeking authorization to conduct sUAS commercial operations.

Further, granting this request will do nothing more than a llow IRQ Technical Labs to do what thousands of hobbyists and manufacturers of model aircraft do every day, except we will abide by much stronger safety measures. under supervision of a certified pilot we would provide a safer level of operation that is su perior to current regulations. This invaluable experience applied to IRQ Technical Labs UAS program equates to safe sUAS use on our projects with no confliction with manned aircraft.Information supporting this Petition as Specified in 14 CFR §11.81

A. Mailing address and other contact information:

IRQ Technical Labs

2618 Ritchie Marlboro Rd

. Upper Marlboro

, MD 20774

GH Turner

301

- 257

- 9334 ghturner@ irqlabs .com

B. The sp ecific section or sections of 14 C.F .R from which IRQ Technical Labs seeks exemption.

14 CFR Part 21 14 CFR 45.23(b) 14 CFR 61.113 (a) & (b)

14 CFR 91.7 (a)

14 CFR 91.9 (b) (2)

14 CFR 91.103

14 CFR 91.109

14 CFR 91.119

14 CFR 91.121

14 CFR 91.203 (a) &(b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

I . STATUTORY AUTHORITY FOR EXEMPTIONS The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory authority includes exempting civil aircraft, as the term is defined under §40101

o f the Act, including sUASs, from the requirement that all civil aircraft must have a

current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or a ny sections 44702

- 44716 of

this title if the Administrator finds the exemption in the public interest. 49 USC

. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a) (1).

S ection 333(b) of the Reform Act assists the secretary in determining whether sUAS may operate in the National Airspace system (NAS) without creating a hazard to the user, the public, or a threat to national security. In making this determination, the Secretary must consider:

• The sUAS's size, weight, speed, and operation al capability; • whether the sUAS operates within the visual line of sight of the operator • whether the sUAS operates outside of highly populated areas and away from close proximity to airportsReform Act §333(a). If the secretary determines that a sUAS "may operate safely in the national airspace system, the secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." Id. §333(c).

IRQ Technical Labs sUAS, weighing less than 55 lbs. includind payload, a nd will operate under normal conditions at a speed of no more than 50 knots. The sUAS will operate only in the Pilot's visual line of sight at all times and will operate only within the preplanned area. such operations will insure that the sUAS will ''not create a hazard to users of the national airspace system or the public." Reform Act section 333 (b).

Given the small size of the sUAS involved and the restricted and preplanned area within which they will operate, our application falls squarely within the zone of safety (an equivalent level of safety) in which congress envisioned that the FAA must, by exemption, allow commercial operations of sUAS to commence immediately. Also due

to the small size of the sUAS and the low altitudes and restricted areas in which the sUAS will operate, approval of the application presents no national security issue.

Given the clear direction in section 333 of the Reform Act, the autho rity contained in the

Federal A viation Act, as amended ; the strong equivalent level of safe ty surrounding the proposed operations, and the significant public benefit, including enhanced safety, the grant of the requested exemptions is in the public interest . Accordingly, IRQ Technical

Labs respectfully requests that the FAA grant the requested exemption without delay.

II. PUBLIC INTEREST

This exemption application is expressly submitted to fulfill congress' goal in passing section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the NAS before completion of the rulemaking required under Section 332 of the Reform Act. By granting an exemption the FAA will fulfill congress's intent of allowing UAS to operate with significant safety pr ecautions in low risk envir onments.

The use of sUAS in a wide variety of site types can significantly reduce the risk to workers of falls while inspecting, survey ing, or monitoring work progress and site

conditions . sUAS can inspect, photograph, and colle ct data on hard to get to areas that otherwise would require direct worker inspection. Falls are a leading source of workplace fatality and injury on construction sites , reducing falls and workplace slips and trips through sUAS use for site imaging could s ave workers lives.

Additionally, sUAS could replace the use of helicopters and small aircraft to perform our

intended tasks. Th e sUAS we propose to fly in this application are under fifty

- five pounds, and carry no combustible mate rial on board, as opposed to much larger conventionally powered small aircraf t. S hifting to sUAS from helicopters and airplanes presents a marked safety increase for workers and the public.Lastly, sUAS reduce the environmental impact by dramatically decreasing the energy

used fo r aeria l imaging and data collection. O ur sUAS use rechargeable lithium ion batteries, as opposed to fossil fuels burned in operation of small aircraft that are many

hundreds of times heavier.

III. EQUIVALENT LEVEL OF SAFETY

IRQ Technical Labs sUAS oper ations will provide a level of safety that far exceeds the level of safety required by the FAA for hobbyists and manufacturers of model aircraft. The following operating procedures will apply during the sUAS inspection operations under this exemption reque st

.

1. IRQ Technical Labs operations will be conducted: i. Within the visual line of sight of the Pilot in command (PIC) and one or more visual Observers (VO).

ii. Within class G airspace

iii. At less than 3 00 feet AGL

.

2. IRQ Technical Labs inspection operations will be conducted in a confined area over isolated private property located at least 4 miles away from any airport, heliport, seaplane base, spaceport or other location with aviation activities, and any military or

U.S. G overnment installations or airfields. If we are within the 4 mile radius of any of the

above installations IRQ Technical Labs will seek written approval from that installation's owner before sUAS operations take place. If said installation owner requires stricter guidelines for o peration then IRQ Technical Labs will comply.

3. All sUAS operations will remain within the lateral and vertical boundaries of the operating area, taking into account all factors, including wind, gross weight and glide distances, that may affect the capab ility of the sUAS to remain within the airspace boundary; moreover, the ceiling height will be no more than 400 feet AGL.

4. IRQ Technical Labs sUAS inspection operations under this exemption will be conducted under the supervision designated PIC who ultim ately has final responsibility for the operation in accordance with 14 CFR 91.3

.

5 . The PIC and vo will maintain two

- way communications with each other during all operations; if unable to maintain two

- way communications, or if any condition occurs

that ma y otherwise cause the operation to be unsafe, the operator will immediately conclude the operation.

6 . Each sUAS that IRQ Technical Labs will employ under this exem ption will safely return automatically to a home location designated by the PIC if the comm unications

link is lost.7 . The aircraft documentation required by 14 CFR §§ 91.9 and 91.203(b), as applicable, will be available to the PIC referred to above at any time IRQ Technical Labs sUAS are operating.

IRQ Technical Labs will effectively operate under our own standard operating procedures that will provide additional safeguards that go far beyond the level of safety for public model airplane fields.

IV . DESCRIPTION OF SPECIFIC REGULATIONS

14 CFR 61.113 (a) &(b): Private pilot privileges and lim itations: Pilot in command

S ections 61.113 (a) &(b) limit private pilots to non

- commercial operations. Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requi ring the Pilot operating the aircraft to have completed a sUAS flight training course of 100 hours before flying a sUAS. unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing or cargo on board. The sUAS are also operated by an autopilot, which greatly reduces the danger of human error. The area of operation 1s controlled and restricted areas, and all flights are planned and coordinated in

advance.

The sUAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured area as set out in the operation plan. Like other civil aircraft, operations under this e xemption will be tightly controlled and monitored by the operator, and in compliance with local public safety requirements, to provide security for the area of operation. The FAA will have advance notice of all operations. The risks associated with the ope ration of the sUAS are therefore diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, and allowing operations of the sUAS as requested with a Pilot who has the level of safety contemplated by 14 C.F .R . §61.113 (a) & (b).

14 CFR 91.103: Preflight Action

This regulation requires each pilot in command take certain actions before flight to ensure the safety of flight. An exemption is needed from this requirement as the Pilot will take separate prefli ght actions, including checking for weather conditions, checking flight battery requirements, checking takeoff and landing distances, and all other actions in the Preflight checklist in the Manual. These actions will provide an equivalent level of safety.

14 CFR 91.119: Minimum safe Altitudes

S ection 91.119 establishes safe altitudes for operation of civil aircraft. section 91.119 (d) allows sUAS to be operated at less than the minimums prescribed, provided the personoperating complies with any route or altitudes prescribed by the FAA. The sUAS will never operate at altitude higher than 400 AGL and will be in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre

- obtained consent.

The equ ivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the location where it is operated. No flight will be taken without the permission of the property owner or local officials. Because of the advance notice to the

p roperty owner and any onsite personnel, all affected individuals will be aware of the planned flight operations. unlike flight operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. proposed herein, our sUAS will not carry flamma ble fuel . In addition, the low

- altitude operations of the sUAS will ensure separation between sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 CFR 91.121: Altimeter settings

This regulation requires ea ch person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "...to the elevation of the departure airport or an appropriate altimeter setting available before departure." As the sUAS may not have a

barometric alti meter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator confirming the altitude of

the launch site shown on the GPS altitude indicator before flight.

14 CFR 91.151 (a): Fuel re quirements for flight in VFR conditions

S ection 91.151 (a) outlines fuel requirements for beginning a flight in VFR conditions. our sUAS is limited to operations in sterile and controlled environments, and has a limited range and flight time which require an exemption from 14 CFR 91.151(a).

The battery powering the sUAS provides approximately 35 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 5 minutes in length. Given the limitations on the sUAS's proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

IRQ Technical Labs believes that an exemption fro m 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin corporation to operate without compliance with FAR 91.151 (a)). operating the small sUAS, in a tightly controlled area where only people and prope rty owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that section 91.151(a) was intended to alleviate given the size and speed of the small UAS. Addit ionally, limiting sUAS flights to 10 minutes would greatly reduce the utility for which the exemption will be granted.An equivalent level of safety can be achieved by limiting flights to 30 minutes, or enough battery reserve to ensure that the sUAS lands at the ground station with at least 20%of battery power (as determined by the onboard monitoring system and the Pilot), whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in i ts limited operating area.

S imilar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 CFR 91.405 (a); 407 (a)(1); 409 (a)(2); 417 (a) &(b): Maintenance inspections

These regulations require that an a ircraft operator or owner "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 . .. ," and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to IRQ Technical Labs . Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook from the manufactural. An equivalent level of safety will be achieved because these small sUAS are very limited in size and will carry a small payload and operate onl y in restricted areas for limited periods of time. If mechanical issues arise the sUAS can land immediately and will be operating from no hi9her than 400 feet AGL. The Pilot will ensure that the sUAS is 1n working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the Pilot is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules: 14 CFR §21, subpart H; 14 C.F.R 45.23(b); 14 CFR §§ 61.113( a) & (b); 91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2) ; 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (SSlbs or less).

Approval of exemptions allowing commercial operations of sUAS in the construction industry enhances safety while reducing risk. Manned aircraft monitoring and surveying creates a greater risk because the craft are much larger, have combustible fuel, and carry an onbo ard human pilot. In contrast, a sUAS weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.The operation of small sUAS, weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide an equivalent level of safety supporting the grant

of the e xemptions requested herein, including exempting the applicant from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a sterile environment and, as a result, are fa r safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people.

Privacy

All flights will occur over private or controlled access property with the property owner's prior consent and knowledge . Images taken will be of individuals who have also consented to being filmed or otherwise have agreed to be in the area where aerial photography will take place .

Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

-- size, weigh t, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security

- provide more than adequate justification for the grant of the requested exemptions allowing commercial operation o f applicant's sUAS.

Sincerely

IRQ Technical Labs

2618 Ritchie Marlboro Rd

. Upper Marlboro

, MD 20774

GH Turner

301

- 257

- 9334 ghturner@ irqlabs .com

sUAS registration FA3RX4HFL7

GH Turner

IRQ Technical Labs www.irqlabs.com

301.613.5346 mobile

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