Soaring Eagle Imaging, LLC. 1 Exemption from Section 333

Soaring Eagle Imaging, LLC Manager: Wi lliam

Paden 133 Glen Arbor Court Brandon, MS 39042 soaringeagleimaging@yahoo.com

To Wh om It May Concern:
Soaring Eagle Imaging, LLC ( its Operating Manager Wi lliam Paden) is requesting an exem

ption from the requirements of 14 C.F .R §§ 6 1.23(a), 61.1 13(a) & (b), 61.195 (b)(1)(2), 91.7(a), 14 CFR Section 21 Subpart H, 91.109, 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)(2), and 91.417(a)(b) , to operate an Unmanned Aircraft System pursuant to Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA). This exemption will permit SEI, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of aerial acquisition and research in support of Government entities, agriculture indus try , utility com

panies, private and government infrastructure, scientific studies, wildlife monitoring, mining, surveying, real estate, aerial photography

, training for UAS operators, and forestry

. SEI, LLC intends to operate the DJI PHANT OM 2+, DJI INSPI RE 1, AURORA FLIGHTSCIENCES SKA TE, and AEYRON SKYRANGER AND SCOUT

. Con sideration of the speed, weight, size, and limited operating area associated with the

unm anned aircraft and its operation are all factors to be considered for this exemption. The DJI Phantom 2+ and DJI Inspire 1 are vertical takeoff and landing (VT OL) Unm anned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2+ has a maximum gross weight of approximately 2 pounds 1 1 o unces, while having a length of 16 inches width of 16Soaring Eagle Imaging, LLC. 2 Exemption from Section 333

inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 1 1.8 inches, and a maximum speed of approximately 42 knots. The DJI Phantom 2 and DJI Inspire 1UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors. The Aurora Flight Sciences Skate is a VTOL winged UA

V that is controlled with a ground station, weighing approximately 2.7 pounds operational. It is approximately 19 inches long by 24 inches wide and is capable of approximately 5

- 50 knots. The Aeyron SkyRanger is a four bladed VTOL system weighing approximately 5.3 lbs

. operational with a diameter of 40 inches deployed. It sits 9.3 inches high. It is controlled by a fully integrated Ground Station. The Aeyron Scout is a smaller four bladed VTOL weighing approximately 3 pounds, 28 inch diam eter deployed, and 8.5 inche s high. It is controlled using a fully integrated ground station. ItsSoaring Eagle Imaging, LLC. 3 Exemption from Section 333 

## TA **BLE OF**

**CONTENTS Page**  GLOSSAR

Y OF ABBREVIA

TIONS................................................................................3

INTRODUCTION AND BACKGROUND OF PETITIONER.........................................4

NAME AND ADDRESS OF PETITIONER......................................................................4

THE SPECIFIC SECTIONS, EXTENT OF RELIEF , AND REASON FOR RELIEF OF 14 C.F .R. FROM WHICH SEI, LLC SEE KS EXEMPTION............................................ 5

THE REASONS WHY

GRANTING SEI, LLC'S REQUESTWOULD BE IN THE PUBLIC INTEREST

.................................................................................................... ...8

THE REASONS WHY

GRA NTING THE EXEMPTION WOULD NOTA DVERSEL Y AFFECTSAFETY

........................................................................................................... ...8

CONCLUSION......................................................................................8Soaring Eagle Imaging, LLC. 4 Exemption from Section 333



## GLOSSAR

**Y OF**  **A BBREVIA** 

**TIONS**
AGL Above Ground Level AOI Area of Interest AT C Air Tr af fic Control AT O Air Tr af fic Organization AV Aerial Ve hicle C.F .R. Code of Federal Regulations COA Certificate of Authorization FAA Federal Av iation Administration FA R Federal Av iation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOT AM Notice to Airman PIC Pilot In Command Section 333 F

AA Modernization and Ref

orm Act of 2012 (FMRA) Section 333 SOP Standard Operating Procedures SEI, Soaring Eagle Imaging, LLC UA Unm anned Aircraft UAS Unm anned Aircraft System VFR Vi sual Flight Rules VLOS Vi sual Line of Site VMC Vi sual Meteorologi cal Conditions VO Vi sual Observer VTOL Ve rtical Takeoff and LandingSoaring Eagle Imaging, LLC. 5 Exemption from Section 333

This petition for the exemption is being entered by W illiam Paden, (Owner and Operator of Soaring Eagle Imaging, LLC) and will provide its clients with expertise and knowledge in advanced technologies and applications to increase efficiency , productivity and effectiveness. Mr. W illiam Paden is a F

AA rated Helicopter Pilot with Airline Tr ansport License privileges; and also a F AA licensed mechanic with Airframe and Powerplant pr ivileges. Mr. Paden has spent many years working in different aspects of aviation from maintenance to operator, civilian and military , in som e of the m ost dem anding situations. The commitment to safety will never be in question. Wi th the granting of this e xemption SEI will be able to safely serve the public and government in varying areas to provide services not previously available or economical. Contact Information Follows: Wi lliam Paden 133 Glen Arbor Court Brandon, MS 39042 soaringeagleimaging@yahoo.com FAA Certificate Num

ber 3370180

**1. Extent Of Relief : SEI, LLC**  **Seek s Relief From Section 61.23 (a)**  Relief from Section 61.23(a): Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section. Until a time in which the F AA determ ines rules pertaining to UAS operators, the PIC for SEI, LLC operations will at a mi nim um m aintain a Class 2 medical. **2. SEI, LLC Seek s Relie**  **f fr om Section 61.1**  **13 (a) (b)** Relief from Section 61.1 13 (a) (b) Private pilot privileges and limitations: Pilot in Command (a) No person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire: nor may thatSoaring Eagle Imaging, LLC. 6 Exemption from Section 333

person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may

, for com pensation 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 com pensation or hire. Due to the size and gross weight of the UAS systems utilized, SEI, LLC will not carry passengers or cargo for hire. Relief fr om this section will not jeopardize safety as all persons designated PIC for SEI, LLC will complete a training program prior to acting as PIC in a manner consistent with the operations specifications as described in this

exem ption and the Tr aining Manual f or SEI, LLC. This includes Emergency Tr aining. **3. SEI, LLC seek** **s Relief from Section 61.195 (b) (1) (2) and Section 91.109**  Relief from Section 61.195 (b) (1) (2) A person who holds a flight instructor certificate is subject to the following limitations (b ) Aircraft Ratings. A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold **(1)** A pilot certificate and flight instructor certificate with the applicable category and class rating, and **(2)** If appropriate, a type rating. Until the F

AA quantifies a category or type rating for UAS systems; All training for UAS operations for SEI, LLC, its Contractors, and Clients will be conducted by trained instructors. The trainer qualifications and training syllabus will be covered in the training manual submitted to the F AA separately for proprietary reasons. The owner and operator of SEI, LLC is an Army trained Instructor Pilot with many years of experience. The training program will center on the safe operations of UAS sys tem s within the NAS.Soaring Eagle Imaging, LLC. 7 Exemption from Section 333

**4. SEI, LLC seek** **s R elief from Section 91.7(a).**  **And 14 CFR Part 21 Subpart H**  Section 91.7(a) Civil aircraft airworthiness. No person may operate a civil aircraft unless it is in an airworthy condition. 14 CFR Part 21 Subpart H Airworthiness Certificates The UASs that SEI, LLC intends to operate are not able to meet multiple requirements set forth in both Sections being requested relief from. Therefore, n o designated PIC for SEI will operate an UAS without first ensuring the syst em is airworthy per the manufacturer manuals and SEI Operations Manual. The operation will terminate if at any point it is determined that the UAS is no longer airworthy

. All operations will follow the guidelines set forth in this exemption. **5. SEI, LLC s**  **eek s Relief from Section 91.121**  Section 91.121 Altimeter Settings. Due to the size and use of the UASs operated by SEI, the capability to have on board Altim eter equipment would make the UAS either too lar ge or heavy to efficiently operate. The systems pro posed to be used by SEI are e quipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of the GCS. This inform ation will be available for AT C as discussed during operations within controlled airspace. All operations in controlled will be outlined in the SEI operations manual submitted confidentially to the F

AA for propr ietary reasons. **6. SEI, LLC seek** **s Relief from Section 91.151** Section 91.151 Fuel requirements for flight in VFR conditions The proposed operations by SEI will be conducted during daylight VMC conditions. Per Section 91.151 no person may begin any flight u nless that person has enough fuel to fly to the first point of intended landing and assuming normal cruising speed, to fly afterSoaring Eagle Imaging, LLC. 8 Exemption from Section 333

that for at least 20 minutes. The systems used my SEI are powered by rechargeable lithium ion batteries. The average flight tim e for all system s, except the Aeyron SkyRanger, is approximately 20 minutes. The SkyRanger has an estimated flight time of 50 m inutes. The SkyRanger will be used as per outlined in the SEI Operations Manual. **7. SEI, LLC seek** **s Relief from section 91.405 (a ), 91.407 (a) (1), 91.409 (a)**  **(1) (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, SEI requests relief from these Sections because the UASs do not require airworthiness certifications. The maintenance program will be overseen by a trained and qualified F AA licensed m echanic with Airframe and Powerplant privileges. The m aintenance program will be outlined in the SEI, LLC Maintenance Operations Manual that will be submitted to the F AA confidentially for proprietary reasons. All m aintenance procedures will adhere to the manufacturer manuals and guidelines. All maintenance will be documented for future inspection by authorized personnel. After any ma intenance is perform ed a flight check will be perform ed as outlined in the SEI, LLC Maintenance Operations Manual. Thank you for your time and consideration in this matter

.
Sincerely , Wi lliam Paden