UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC
Regulatory Docket No. _______________

**IN THE MATTER OF THE PETITION FOR EXEMPTION OF:**

**SAWYER INFRARED FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS**  **OF**

**TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2),**  **AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF THE DJI SPREADING** 

**WINGS S900 UNMANNED AIRCRAFT SYST** **EM PURSUANT TO SECTION 333 OF**  **THE FAA MODERNIZ ATION AND REFORM ACT OF 2012 (PUBLIC LAW**  **112 -** **95)**

Submitted on July

13, 2015 Zachary T. Lesinski O/B/O Sawyer Infrared 14 Newbury St, Peabody, MA 01960

### Sawyer	Infrared Page 2

**TABLE OF CONTENTS** Page GLOSSARY OFABBREVIATIONS
................................................................................. 3 SUMMARY........................................................
................................................................. 4 INTRODUCTION AND INTERESTS OF PETITIONER
................................................ 4 BACKGROUND
................................................................................................................ 4 BASIS FOR PETITION ..................................
.................................................................... 4 NAME AND ADDRESS OF PETITIONER.................................................................
..... 6 THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH SAWYER INFRARED SEEKS EXEMPTION
....................................................................................................... 7 THE EXTENT OF RELIEF SAWYER INFRARED SEEKS AND THE REASON SAWYER INFRARED SEEKS THE RELIEF................
................................................... 10 THE REASONS WHY GRANTING SAWYER INFRARED'S REQUEST WOULD BE IN THE PUBLIC INTEREST .....................................................................................
....... 13 THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY..............................................................................
....... 15 SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER..........
....... 27 ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT SAWYER INFRARED'S REQUEST .......................
................................. 27 CONCLUSION................................................................................................................. 28

### Sawyer	Infrared Page 3 **GLOSSARY OF ABBREVIATIONS** AGL Above Ground Level AOI Area of Interest ATC Air Traffic Control ATO Air Traffic Organization C.F.R. Code of Federal Regulations COA Certificate of Authorization FAA Federal Aviation Administration FAR Federal Aviation Regulation FCC Federal Communications Commission GCS Ground Control Station GPS Global Positioning System NAS National Airspace System NOTAM Notice to Airmen OEM Original Equipment Manufacturer PIC Pilot In Command RTH Return To Home Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333 UA Unmanned Aircraft UAS Unmanned Aircraft System VFR Visual Flight Rules VLOS Visual Line of Sight VMC Visual Meteorological Conditions VO Visual Observer VTOL Vertical Takeoff and Landing

### Sawyer	Infrared Page 4

**SUMMARY** Sawyer Infrared seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 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 (FMRA). This exemption will permit Sawyer Infrared to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting infrared inspection services and optical gas imaging within the National Airspace System (NAS). **INTRODUCTION AND INTERESTS OF THE PETITIONER**  Sawyer Infrared (hereinafter referred to as “Sawyer Infrared”) is an infrared inspection service and optical gas imaging consulting company, specializing in using state-of
-the
-art high
-resolution infrared camera technology f

or various industries, including optical gas imaging, water and leak detection, critical infrastructure industry inspections, commercial building, and roof surveys. Sawyer Infrared is headquartered in Peabody, Massachusetts. **BACKGROUND** Unmanned Aircraft System: Spreading Wings S900 UAS Sawyer Infrared seeks an exemption to operate the DJI Spreading Wings S900 UAS for compensation or hire within the NAS. The Spreading Wings S900 UAS is comprised of a vertical takeoff and landing (VTOL) Unmanned Aerial System (UAS) and a transportable Ground Control Station (GCS). The Spreading Wings S900 UAS has a maximum gross weight of approximately 7.3 pounds; measures approximately 18 inches in length, 17 inches in width, and 14 inches in height; and has maximum speed of approximately 35 miles per hour
. The Spreading Wings S900 UAS is equipped with six (6) rotor wings, each being driven by a Lithium Polymer battery
-powered electric motor. The Spreading Wings S900 UAS that will be operated by Sawyer Infrared will be registered in accordance with 49 U.S.C. 44103, Registration ofAircraft, as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking
. **BASIS FOR PETITION** The Petitioner, Sawyer Infrared, by and through undersigned counsel, pursuant to the provisions ofthe 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

### Sawyer	Infrared Page 5

operate the Spreading Wings S900 UAS within the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 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, Sawyer Infrared’s operation of the Spreading Wings S900 UAS meets the conditions ofFMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Accordingly, Sawyer Infrared requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. Sawyer Infrared submits that the requested relief is proper since an equivalent level of safety will be ensured. All maintenance, alterations, or preventive maintenance of the Spreading Wings S900 UAS performed by Sawyer Infrared will be in accordance with the methods, techniques, and practices prescribed in the operating documents (i.e., the Spreading Wings S900 User Manual, the Spreading Wings S900 Release Notes and t

he A2 Flight Control System User Manual). Furthermore, only the Original Equipment Manufacturer (OEM) or qualified OEM maintainers will perform higher
-level inspections and maintenance per the operating documents and OEM standards. Sawyer Infrared will document and maintain all maintenance records for the Spreading Wings S900 UAS. Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command, is requested by Sawyer Infrared to the extent necessary to allow the proposed UAS flight operations to be conducted by a Pilot in Command (PIC) holding a private pilot certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight
-hour and currency requirements, that the PIC is able to safely operate the Spreading Wings S900 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Sawyer Infrared seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the Spreading Wings S900 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Sawyer Infrared submits that it will ensure that the Spreading Wings S900 UAS is in an airworthy condition, prior to every flight, by determining that the UAS is in compliance with the operating documents (i.e., the Spreading Wings S900 User Manual, the Spreading Wings S900 Release Notes and t he A2 Flight Control System User Manual), and that the aircraft is in a condition for safe flight.

### Sawyer	Infrared Page 6

Sawyer Infrared also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, because the altitude reporting equipment ofthe Spreading Wings S900 UAS is set to zero feet above ground level (AGL), rather than local barometric pressure or field altitude, before each flight. The altitude information of the Spreading Wings S900 UAS is provided to the PIC via a barometric pressure sensor, Global Positioning System (GPS) equipment, and a radio communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring of the flight path. A level of safety equivalent to Section 91.121 will be ensured as the altitude of the Spreading Wings S900 UAS will be reported to air traffic control (ATC) in feet AGL, and Sawyer Infrared will operate the Spreading Wings S900 UAS within visual line of sight, at or below 400 feet AGL. Additionally, Sawyer Infrared seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions
. Sawyer Infrared submits that safety will not be affected by operation of the Spreading Wings S900 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR)
. The Spreading Wings S900 contains enough battery power to fly for a total duration of 18 minutes, however, Sawyer Infrared will fly the UAS for no longer than 14.4 minutes to the first point of intended landing, assuming normal cruising speed, and will reserve approximately 3.6 minutes of flight time for safety precautions (i.e., 20 percent battery power remaining). In accordance with 14 C.F.R. § 11.81, Sawyer Infrared provides the following information in su pport of its petition for exemption: **A. Name And Address Of The Petitioner.**  The name and address of the Petitioner is: Sawyer Infrared 14 Newbury Street Peabody, MA 01960 The point of contact for this Petition and specific contact information is as follows: Zachary T. Lesinski Tel: (508) 280
-4252 246 South Meadow Rd Gate 6 Building S
-2 Plymouth MA, 02644 Email: ztl@avwatch.us

### Sawyer	Infrared Page 7

**B. The Specific Sections Of 14 C.F.R. From Which**  **Sawyer Infrared Seeks Exemption.**  **1. Sawyer Infrared**  **Seeks Exemption From The Req uirements Of Section 61.113(a) And (b).**  Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections (a) and (b) prescribe the following, in relevant part: (a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. **2. Sawyer Infrared**  **Seeks Exemption From The Requirement s Of Section 91.7(a).**  Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it is in an airworthy condition. **3. Sawyer Infrared**  **Seeks Exemption From The Requirements Of Section 91.121.**  Section 91.121, entitledAltimeter settings, subsection (a), states the following, in part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating
-- (1) Below 18,000 feet MSL, to-- (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragra ph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

### Sawyer	Infrared Page 8

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; **4. Sawyer Infrared**  **Seeks Exemption From The Requirements Of Section 91.151(b).** Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) No person may begin a flight in a rotorcraft 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, to fly after that for at least 20 minutes.
**5. Sawyer Infrared**  **Seeks Exempt ion 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 [.] **6. Sawyer Infrared**  **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 [.] **7. Sawyer Infrared**  **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
--

### Sawyer	Infrared Page 9

(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 (2)An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. **8. Sawyer Infrared**  **Seeks Exemption From The Requireme nts 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 oflife
-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.

### Sawyer	Infrared Page 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**  **Sawyer Infrared Seeks And The Reason**  **Sawyer Infrared Seeks The Relief.**  **1. Extent**  **of Relief**  **Sawyer Infrared**  **Seeks And**  **The Reason**  **Sawyer Infrared**  **Seeks Relief**  **From Section**  **61.113(a) And (b).** Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command, is requested to the extent necessary to allow a PIC holding a private pilot certificate, as well as an airman medical certificate, and who has met certain flight
-hour and currency requirements, to conduct the proposed UAS flight operations for compensation or hire. This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire. As set forth more fully below, Sawyer Infrared submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the Spreading Wings S900 UAS unless that PIC has met certain flight
-hour and currency requirements, demonstrating that the PIC is able to safely operate the Spreading Wings S900 UAS in a manner consistent with the operations specifications as set forth herein, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and structures.

### Sawyer	Infrared Page 11

Further, Sawyer Infrared submits that all flights of the Spreading Wings S900 UAS, conducted by the PIC pursuant to the grant ofthis Petition: (1) will be incidental to Sawyer Infrared’s business; and (2) will not carry passengers or property for compensation or hire.

**2. Exte** **nt of**  **Relief Sawyer**  **Infrared Seeks**  **And The**  **Reason Sawyer**  **Infrared Seeks**  **Relief From**  **Section 91.7(a).**  Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow Sawyer Infrared to determine that the Spreading Wings S900 UAS is in an airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Spreading Wings S900 User Manual, the Spreading Wings S900 Release Notes and the A2 Flight Control System User Manual). Sawyer Infrared seeks the requested relief because the Spreading Wings S900 UAS does not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Sawyer Infrared will ensure that the Spreading Wings S900 UAS is in an airworthy condition based upon its compliance with the operating documents prior to every flight, and further, determine the aircraft is in a condition for safe flight, as stated in the conditions and limitations below.

**3. Extent**  **of Reli** **ef Sawyer**  **Infrared Seeks**  **And The**  **Reason Sawyer**  **Infrared Seeks**  **Relief From**  **Section 91.121.**  Relief from Section 91.121, entitledAltimeter settings, may be required to allow flight operations of the Spreading Wings S900 UAS, because the Spreading Wings S900 UAS’s altitude reporting equipment may be set on the ground to zero feet AGL, rather than local barometric pressure or field altitude, before each flight. The Spreading Wings S900 UAS utilizes a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UAS to the PIC at the ground control station (GCS). Considering the limited altitude of the proposed operations, relief from 14 C.F.R. § 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, a level of safety equivalent to Section 91.121 will be ensured as the altitude of the Spreading Wings S900 UAS will be reported to air traffic control (ATC) in feet above ground level (AGL), and Sawyer Infrared will operate the Spreading Wings S900 UAS within visual line of sight, at or below 400 feet AGL.

### Sawyer	Infrared Page 12

**4. Extent**  **Of**

**R elief**  **Sawyer Infrared**  **Seeks And**  **The Reason**  **Sawyer Infrared**  **Seeks Relief**  **From Section**  **91.151(b ).**  Relief from Section 91.151(b) entitled Fuel requirementsforflight in VFR conditions, is requested to the extent required to allow flights of the battery powered Spreading Wings S900 UAS during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR)
. The Spreading Wings S900 contains enough battery power to fly f or a total duration of 18 minutes, however, Sawyer Infrared will fly the UAS for no longer than 14.4 minutes to the first point of intended landing, assuming normal cruising speed, and will reserve approximately 3.6 minutes of flight time for safety precautions (i.e., 20 percent battery power remaining). Sawyer Infrared seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered Spreading Wings S900 UAS will severely constrain the practicality of any aerial acquisition and research flight operations that Sawyer Infrared proposes to conduct pursuant to this Petition. Significantly, as set forth below, the technical specifications of the Spreading Wings S900 UAS, the Spreading Wings S900 UAS operating documents, and Sawyer Infrared’s proposed operating limitations, ensure that Sawyer Infrared will safely operate the battery powered Spreading Wings S900 UAS during daylight hours in visual meteorological conditions (VMC) under visual flight rules (VFR). The Spreading Wings S900 contains enough battery power to fly f or a total duration of 18 minutes, however, Sawyer Infrared will fly t he UAS for no longer than 14.4 minutes to the first point of intended landing, assuming normal cruising speed, and will reserve approximately 3.6 minutes of flight time for safety precautions (i.e., 20 percent battery power remaining).
**5. Extent Of Relief**  **Sawyer Infrared See** **ks And The Reason**  **Sawyer Infrared 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, Sawyer Infrared requests relief from these Sections because the Spreading Wings S900 UAS does not require an airworthiness certificate. As set forth more fully below, the Spreading Wings S900 UAS meets the conditions of Section 333 of the FMRA for operation without an airworthiness certificate. All maintenance, alterations, or preventive maintenance on the UAS of the Spreading Wings S900 UAS performed by Sawyer Infrared will be in accordance with the methods, techniques, and practices prescribed in the operating documents (i.e., the Spreading Wings S900 User Manual, the Spreading Wings S900 Release Notes and the A2 Flight Control System User Manual). Furthermore, only t he Original

### Sawyer	Infrared Page 13

Equipment Manufacturer (OEM) or qualified OEM maintainers will perform higher
-level inspections and maintenance per the operating documents and OEM standards. Sawyer Infrared will document and maintain all maintenance records for the Spreading Wings S900 UAS.

**D. The**  **Reasons Why**  **Granting Sawyer**  **Infrared ’s**  **Request Woul** **d 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 Sawyer Infrared to safely, efficiently, and economically perform infrared inspection services and optical gas imaging within the NAS, commercially, in support of various clients including environmental firms, hotels, construction companies, critical infrastructure corporations including oil, gas and electricity providers, and local military bases including the United States Coast Guard Base in Boston, Massachusetts and the Otis Air Force Reserve Base located in Bourne, Massachusetts
. Additionally, use of the Spreading Wings S900 UAS will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the economy. Notably, the benefits of Sawyer Infrared’s proposed operation of the Spreading Wings S900 UAS will be realized without implicating any privacy issues. **1. The Public Will Benefit From The Aerial Acquisition And Research Performe** **d.** Sawyer Infrared submits this Petition to commercially operate the Spreading Wings S900 UAS and perform aerial acquisitions within the NAS, in support ofenvironmental firms, hotels, construction companies, critical infrastructure corporations including oil, gas and electricity providers, and local military bases
. The Spreading Wings S900 UAS will provide safe, efficient, and economical aerial acquisition and research operations to further each of these fields, all of which are critical to the well
-being and safety of the general public. The specific operations that Sawyer Infrared will perform with the Spreading Wings S900 UAS demonstrate how the requested exemption will directly benefit the above
-referenced industries and the public. More specifically, in the oil and gas industries, the Spreading Wings S900 UAS will be used to aid in facility safety and compliance inspections
. Inspections of facilities include roofs, solar panels, windmill blades, facades, bridges, liquid nitrogen gas storage tanks, elect rical transmission towers, power lines and substations, agricultural crops, gas pipelines, and petroleum storage tanks. The Spreading Wings S900 UAS will further environmental management by determining threats of oil and gas pollution, as well as mapping oil and gas spills or other types of land and water contamination
. **2. The Public Will Benefit From Decreased Congestion Of The NAS.** 

### Sawyer	Infrared Page 14

The Spreading Wings S900 UAS is battery powered and serves as a safe, efficient, and economical alternative to utilizing manned aircraft to obtain this type ofaerial imagery. By reducing the amount of manned aircraft needed to perform aerial photography, an exemption allowing the use of a Spreading Wings S900 UAS would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, and 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 Spreading Wings S900 UAS 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**  **Spreading Wings S900 UAS.**  Conducting aerial acquisitions with the Spreading Wings S900 UAS, instead ofmanned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial imaging flights. By using battery power and electric motors, the Spreading Wings S900 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 ty pically utilized for aerial imagery, and burn approximately 20
-30 gallons per hour of leaded aviation fuel. The Spreading Wings S900 UAS, while reducing the carbon footprint of aerial acquisitions, also reduces noise pollution, as the UAS is propelled by battery powered electric motors, rather than an internal combustion engine. By using the Spreading Wings S900 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 offlight crew members located onboard the aircraft, the Spreading Wings S900 UAS (weighing approximately 7.3 pounds; measuring approximately 18x17x14; and carrying 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 ty pically conduct aerial imagery (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**  **Oper ations**  **With The**  **Spreading Wings**  **S900 UAS**  **Will Benefit**  **The Economy.** In addition to being safe and efficient, the Spreading Wings S900 UAS is also an economical alternative to using manned aircraf t to conduct aerial imagery
. As such, operation of the Spreading Wings S900 UAS will allow United States
-based companies, like Sawyer Infrared, to remain competitive and

### Sawyer	Infrared Page 15

contribute to growth of the United States economy. In employing infrared inspection services and optical gas imaging, Sawyer Infrared ensures that environmental agencies, hotels, construction companies, critical infrastructure corporations, military bases are able to operate effectively and safely, which ultimately prevents death, injury, or other company liabilities which would lead to personal hardship and loss of business. Additionally, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, United States
-owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered Spreading Wings S900 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. By operating the Spreading Wings S900 UAS, companies such as Sawyer Infrared can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the United States economy. Improved financial performance ofUnited States companies, through commercial use of the Spreading Wings S900 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.**  Similar to the manned aerial acquisition flight operations that have been conducted for decades, Sawyer Infrared’s proposed operation of the Spreading Wings S900 UAS will not implicate any privacy issues. Specifically, the Spreading Wings S900 UAS will only be operated pursuant to the specific conditions and limitations set forth herein, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119. Most significantly, the Spreading Wings S900 UAS will not be operated closer than 500 feet to any person, vessel, vehicle, or structure, which is not directly involved in the operation.
**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**  **S awyer Infrared**  **Seeks Exemption. 1.**  **Reasons Why The Spreading Wings S900**  **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, Sawyer Infrared’s operation of the Spreading Wings S900 UAS meets the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21,

### Sawyer	Infrared Page 16

Subpart H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth 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. Specifically, FMRA Section 333 states the following, in part: (a) In General.

--Notwithstanding any other requirement ofthis subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircra ft 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 ofwaiver, certificate ofauthorization, or airworthiness certification under section 44704 of title 49, United States Code, is requiredfor the operation ofunmanned aircraft systems identified under paragraph (1). (c) Requirements for Safe Operation.

--Ifthe Secretary determines under this section that certain unmanned aircraft sy

stems 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, Sawyer Infrared submits that the Spreading Wings S900 UAS can operate safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of the Spreading Wings S900 UAS; (b) the pilot certification requirement; and (c) the specific operating limitations.

**a. The Specifications Of**  **The Spreading Wings S900**  **UAS Demonstrate Its Safe Characteristics.** The Spreading Wings S900 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, and operational capability. **i. Technical Specifications Of The**  **Spreading Wings S900 UAS.**  The technical specifications of the Spreading Wings S900 UAS are set forth at pages 22
-23 of the Spreading Wings S900 User Manual, attached hereto as Exhibit A. Exhibit A contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b)1.

### Sawyer	Infrared Page 17

**ii. The**  **Spreading Wings**  **S900 UAS**  **Is Manufactured**  **For Safety**  **and Reliability** **.** The Spreading Wings S900 UAS is built with a strong carbon fiber frame, designed to greatly reduce weight while increasing stability and strength under various, tested flight and temperature conditions. It also contains an advanced power distribution board, which improves reliability and safety during flight. The Spreading Wings S900 is also manufactured with a unique screw design to secure power cords and is equipped with a spark
-proof plug to prevent short circuits in flight. The UAS’ six motors located on each arm are comprised of a single
-wire stator design, which improves heat dissipation for a more dependable system. Each arm is also designed with an 8
-degree inversion and a 3
-degree inclination, making the UAS more stable and controllable when rolling and pitching, and flexible when rotating during flight. Sawyer Infrared understands that the maximum flight time of 18 minutes of the Spreading Wings S900 was tested during low
-wind weather conditions, with a payload of 14.9lbs, while hovering at a height of 6.5 feet. The safety features of the Spreading Wings S900 UAS are set forth in the Spreading Wings S900 User Manual, the Spreading Wings S900 Release Notes and the A2 Flight Control System User Manual attached hereto as Exhibit A. Exhibit A contains proprietary information and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b)1.
**iii. The**  **Spreading Wings S900 GCS And Its Operation.**  The Spreading Wings S900 UAS is compliant with all Federal Communications Commission (FCC) requirements, and the radio frequency spectrum used for operation and control of the UAS is set forth at page 31 of the Spreading Wings S900 UAS User Manual. A copy of the Spreading Wings S900 User Manual, which contains proprietary information, is attached hereto as Exhibit A, and is to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). **b. Flight**  **Operati ons**  **Of T** **he Spreading**  **Wings S900**  **UAS Are**  **Limited To**  **The Line**  **Of S** **ight Of** 

**A Certificated Pilot in Command With**  **A Safety Observer.** Sawyer Infrared will only utilize certificated pilots who possess a current and valid FAA issued airman medical certificate to act as a pilot in command (PIC) of the Spreading Wings S900 UAS. Additionally, a safety observer will assist all pilots during flight operations.

**c. Flights**  **Of**

**T he**  **Spreading Wings**  **S900 UAS**  **Will Be**  **Conducted Pursuant**  **To Specific**  **Operating Limitations.**  In seeking this exemption, Sawyer Infrared proposes to commercially operate the Spreading Wings S900 UAS for the special purpose of conducting infrared inspection services and optical gas imaging within the NAS, pursuant to the following specific operating limitations:

### Sawyer	Infrared Page 18

1. Operations authorized by this grant of exemption are limited to the following aircraft described in the operating documents, which is a hexa
-rotor aircraft weighing less than 8 pounds at maximum gross weight: DJI Spreading Wings S900 Unmanned Aerial System. Proposed operations of any other aircraft will require a new petition or a petition to amend this grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial acquisitions. 3. The UAS may not be flown at an indicated airspeed exceeding 30 knots. 4. The UAS must be operated at an altitude ofno more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operating documents. All altitudes reported to ATC must be in feet AGL. 5. The UAS must be operated within visual line of sight (VLOS) ofthe PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA
-issued airman medical certificate. 6. The use of first person view (FPV) by the PIC or visual observer (VO) is not permitted. 7. All operations must utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS ca pability. The VO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the functions prescribed in the operating documents. 8. The VO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate the camera or other instruments. 9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents ifit petitions for extension or amendment to the grant of exemption. Ifthe operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition

### Sawyer	Infrared Page 19

for amendment to the grant of exemption. The FAA’s UAS Integration Office (AFS
-80) may be contacted if questions arise regarding updates or revisions to the operating documents. 10. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. 14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 15. Each UAS operated under this exem ption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections. 17. The PIC must possess at least a private pilot certificate and at least a current third
- class medical certificate. The PIC must also meet the flight review requirements specified in 14 C.F.R. § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). The VO is also required to complete the operator’s training requirements. A record of training must be documented and made available upon request by the Administrator.

### Sawyer	Infrared Page 20

Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience
building), are permitted under the terms of the exem ption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience
-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119.
19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 20. The UAS may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA
-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by t he operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request. 21. The UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 22. If the UAS loses communications or loses its GPS signal, it must return to a pre- determined location within the planned operating area and land or be recovered in accordance with the operating documents. 23. The PIC must abort the flight in the event ofunpredicted obstacles or emergencies in accordance with the operating documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UAS with 20% battery power remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airmen (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements.

### Sawyer	Infrared Page 21

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N
- Num ber) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable
. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UAS must comply

with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements. 28. The documents required under 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
29. The UAS must remain clear and yield the right of way to all manned aviation operations and activities at all times. 30. The UAS may not be operated by the PIC from any moving device or vehicle. 31. The UAS may not be operated over congested or densely populated areas. 32. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, VO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UAS and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet of the UAS, flight operations must cease immediately and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, VO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a). 33. All operations shall be conducted over private or controlled
-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted.

### Sawyer	Infrared Page 22

34. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by t he applicable COA must be reported to the FAA's UAS Integration Office (AFS
-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

**2. Reasons**  **Why An**  **Exemption From**  **The Requirements**  **Of Section**  **61.113(a) And**  **(b) Would**  **Not Adversely Affect Safety.**  Sawyer Infrared submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the Spreading Wings S900 UAS unless that PIC has demonstrated, by

meeting minimum flight
-hour and currency requirements, that the PIC is able to safely operate the Spreading Wings S900 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Considering Sawyer Infrared’s proposed area of operations, and the operating limitations set forth
above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the Spreading Wings S900 UAS, Sawyer Infrared submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Sawyer Infrared ’s specific proposed flight operations. The Spreading Wings S900 UAS has been the subject of multiple Grants of Exemption from Section 61.113(a) and (b) (Exemption Nos. 11153, 11157). Additionally, the FAA has previously granted relief from Section 61.113(a) and (b) 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, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161, 11170, 11171, 11172). Sawyer Infrared will not allow any PIC to operate the Spreading Wings S900 UAS unless that PIC has demonstrated, by meeting minimum flight
-hour requirements or the Spreading Wings S900 UAS training and currency requirements, that the PIC is able to safely operate the Spreading Wings S900 UAS in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot

### Sawyer	Infrared Page 23

with a multi
-rotor UAS (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 take
-offs and landings in the preceding 90 days (for currency purposes). As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Sawyer Infrared’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picturefilming (or similar operations), the PIC must have accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UASpilot with a multi

-rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of5 hours as a UASpilot operating the same make and model ofUAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours ofmulti

-rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to t

he hour requirements, the PIC must accomplish 3 take

-offs and landings in thepreceding 90 days (for currency purposes). The FAA finds that at a minimum, theflight

-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training,proficiency, and experience
-buildingflights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience
-building flights the PIC is required to operate the UAS with appropriate distances in accordance with 14 C.F.R 91.119. Exemption No. 11138 at page 15. Accordingly, Sawyer Infrared will ensure safe operations by not allowing any PIC to operate the Spreading Wings S900 UAS unless that PIC has demonstrated, by meeting minimum flight
-hour and currency requirements, that the PIC is able to safely operate the Spreading Wings S900 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. **3. Reasons**  **Why An Exemption From**  **The Requirements Of Section**  **91.7(a) Would**  **Not Adversely Affect Safety.** The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Sawyer Infrared will ensure that the Spreading Wings S900 UAS is in an airworthy condition based

### Sawyer	Infrared Page 24

upon the Spreading Wings S900 UAS’ compliance with its operating documents (i.e., the Spreading Wings S900 User Manual, the Spreading Wings S900 Release Notes and the A2 Flight Control System User Manual), and as stated in the conditions and limitations herein. The Spreading Wings S900 UAS has been the subject of multiple Grants of Exemption from Section 91.7(a) (Exemption Nos. 11153, 11157). Additionally, the FAA has previously granted relief from Section 91.7(a) 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, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 11172). **4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect**  **Safety.**The equivalent level of safety established by Section 91.121 will be maintained because the altitude of the Spreading Wings S900 UAS will be reported to air traffic control (ATC) in feet above ground level (AGL), and Sawyer Infrared will operate the Spreading Wings S900 UAS within visual line of sight, at or below 400 feet AGL
. Furthermore, the altit ude information of the Spreading Wings S900 UAS will be provided to the PIC via a barometric pressure sensor, GPS equipment and a radio communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring of the flight path and altit ude. Prior to each flight, a zero altitude initiation point is automatically established by the UAS at ground level. The Spreading Wings S900 UAS was the subject of multiple Grants of Exemption from Section 91.121 (Exemption Nos. 11153, 1157). The FAA has previously granted relief from Section 91.121 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, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171). **5. Reasons**  **Why An**  **Exemption From**  **The Requirements**  **Of Section**  **91.151(b) Would**  **Not Adversely Affect Safety.**  A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the Spreading Wings S900 UAS; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Sawyer Infrared will ensure that it will safely operate the battery powered Spreading Wings S900 UAS during daylight hours in visual metrological conditions (VMC) under visual flight rules (VFR). The Spreading Wings S900 contains enough battery power to fly f or a total duration of 18 minutes, however, Sawyer Infrared will fly the UAS for no longer than 14.4 minutes to the first point of intended landing, assuming normal cruising speed,

### Sawyer	Infrared Page 25

and will reserve approximately 3.6 minutes of flight time for safety precautions (i.e., 20 percent battery power remaining). Here, as in Exemption No. 11109, the technical specifications of the Spreading Wings S900 UAS; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the Spreading Wings S900 UAS provides audible and visual warnings to the PIC at the GCS when the UAS has low battery power remaining. Significantly, the Spreading Wings S900 UAS has been the subject of multiple Grants of Exemption from Section 91.151 (Exemption Nos. 11153, 11157), and other previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations ofthe UAS are considered. Reliefhas been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 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, 11109, 11110, 11136, 11 138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 11172). **6. Reasons**  **Why An**  **Exemption From**  **The Requirements**  **Of Sections**  **91.405(a), 91.407(a)(1),**  **91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect S afety.**  In seeking this exemption, Sawyer Infrared submits that the equivalent 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), and 91.417(a) & (b) will be met because all maintenance, alterations, or preventive maintenance ofthe Spreading Wings S900 UAS performed by Sawyer Infrared will be in accordance with the methods, techniques, and practices prescribed in the operating documents (i.e., the Spreading Wings S900 User Manual, the Spreading Wings S900 Release Notes and the A2 Flight System User Manual). Furthermore, only the Original Equipment Manufacturer (OEM) or qualified OEM maintainers will perform higher
-level inspections and maintenance per t he operating documents and OEM standards. Sawyer Infrared will document and maintain all maintenance records for the Spreading Wings S900 UAS. Since the Spreading Wings S900 UAS will be inspected as prescribed by t he operating documents, Sawyer Infrared will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). The following operating documents are attached hereto, identified as the following Exhibit: (A) the Spreading Wings S900 User Manual, the Spreading Wings S900 Release Notes and the A2 Flight

### Sawyer	Infrared Page 26

Control System User Manual
. The foregoing exhibits contain proprietary information and are to be held in a separate file pursuant to 14 C.F.R. § 11.35(b). Likewise, the exemption sought will not adversely affect safety because all maintenance, alterations, or preventive maintenance of the Spreading Wings S900 UAS will be performed by DJI in accordance with the methods, techniques, and practices prescribed in the operating documents. Only the Original Equipment Manufacturer (OEM) or qualified OEM maintainers will perform higher
-level inspections and maintenance per the operating documents and OEM standards. Sawyer Infrared will document and maintain all maintenance records for the Spreading Wings S900 UAS. Furthermore, an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because Sawyer Infrared will document and maintain all of the maintenance records for the Spreading Wings S900 UAS. The Spreading Wings S900 UAS has been the subject of multiple Grants of Exemption from Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b) (Exemption Nos. 11153, 11157), and other previous exemptions granted by t he FAA concerning these Sections establish that safety is not adversely affected when the technical characteristics and operating limitations of the UAS are considered (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161, 11166, 11167, 11170, 11171, 11172).
**7. 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, Sawyer Infrared requests that the FAA prescribe special conditions for the intended operation of the Spreading Wings S900 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 §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 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 UAS for the limited purpose of conducting aerial acquisitions within the NAS for compensation or hire. 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 in accordance with any requirements that must be established for the safe operation of the UAS in the NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R.§ 21.16, for operation of the Spreading Wings S900 UAS, since the airworthiness regulations of 14 C.F.R. Part 21 do not

### Sawyer	Infrared Page 27

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: Ifthe FAAfinds that the airworthiness regulations ofthis subchapter do not contain adequate or appropriate safety standardsfor an aircraft, aircraft engine, orpropeller because ofa novel or unusual designfeature 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 ofthis chapter and contain such safety standard sfor the aircraft, aircraft engine orpropeller as the FAAfinds 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 Sawyer Infrared’s intended operation ofthe Spreading Wings S900 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 Section 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 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 Sawyer**  **Infrared Seeks Exemption:**  Sawyer Infraredseeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 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 Ex emption**  **Sawyer Infrared Seeks:**  This exemption will permit Sawyer Infrared to commercially operate an Unmanned Aircraft System (UAS) for the purpose of conducting infrared inspection services and optical gas imaging within the National Airspace System (NAS)

. **G. Any**  **Additional Information,**  **Views, Or**  **Arguments Available**  **To Support**  **Sawyer Infrared** **’s Request.**  This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary ofTransportation to determine ifcertain UAS may operate safely in the NAS. As such, Sawyer Infrared’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.

### Sawyer	Infrared Page 28

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, Sawyer Infrared will operate the Spreading Wings S900 UAS 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, Sawyer Infrared 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 Spreading Wings S900 UAS commercially, without an airworthiness certificate, for the limited purpose of conducting infrared inspection services and optical gas imaging within the National Airspace System (NAS). 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 Sawyer Infrared to safely, efficiently, and economically operate the Spreading Wings S900 UAS commercially within the NAS. **WHEREFORE**, in accordance with the Federal Aviation Regulations and the FAA Modernization a nd Reform Act of 2012, Section 333, Sawyer Infrared respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit Sawyer Infrared to operate the Spreading Wings S900 UAS commercially for the purpose of conducting aerial acquisitions within the NAS.