U.S. Department ofTransportation Docket ManagementSystem 1200 NewJersey Avenue, S.E. West Building Ground Floor, Room W12-140 Washington, DC 20590



## Petition for Exemption under Section 333 ofthe FAA Modernization and Reform Act and Part 11.81 ofthe Federal Aviation Regulations

May 

### 5, 2015

Petitioner: Utilis Engineering, PA Jon Owen, EVP Corporate Development 1300 S. Dekalb Street Shelby, NC 28152 Tel.: 704.751.1790 Email: jowen@utilisdesign

.com Website: www.utilisdesign.com

Dear Sir or Madam,
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11.81, Utilis Engineering, PA, hereby appliesfor an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation ofits small, unmanned aircraft for photogrammetry, inspection, and analyses. All operations shall be conducted within and underthe conditions and limitations outlined previously by the FAA as required by Section 333 and conducted in compliance with the attached operator'smanuals.

1. Sections from which exemptions are sought: Application is hereby made for exemption from:

a. 14 CFR Part 21, subpart H b. 14 CFR Part 61.113(a) and (b)
c. 14 CFT Part 91:

2. Reliefsought: i. 91.103{b)(2) ii. 91.105 iii. 91.109 iv. 91.119

v. 91.121 vi. 91.151 vii. 91.405 viii. 91.407

ix. 91.409
X. 91.417

a

. Utilis Engineering, PA wishes to operate small Unmanned Aircraft Systems (sUAS) for commercial purposes to include (but not be limited to) photogrammetry, industrial inspections andanalyses.This relief is sought because commercial use ofsUAS is currently prohibited by lawunless performed under an exemption. b. This exemption will cover use ofthe following airframes, all ofwhich will weigh less than55 pounds including payload and energy sources: i. DJIInspire 1- www.dji.com/product/inspire-1/spec ii. Other models to be added by future amendmentto this exemption. 3. Public benefit:
a. Use ofsUAS technology to obtain imagery, information and data currently obtained by useof manned flight or manual methods: i. Reduces statistical risk to human life due to manned aircraft accidents (e.g., infrastructure inspections) and due to other dangerous activities that can beavoided (e.g., scaffolding/rigging failures during stack or bridge inspections). ii. Reduces the cost ofobtaining such information, which benefits consumers andthe economy. iii. Reduces environmental impact by eliminatingsources ofhydrocarbon emissions from manned aircraft. 4. Safety not adversely affected:
a. Aircraft will be registered and marked in accordance with Section 44711 and Part 47 and Part45, Subpart 

### C. b. Aircraft will comply with maintenance and inspection requirements ofthe manufacturer. All repair and maintenance work will be conducted or approved by qualified personnel such asthose authorized by Robotic Skies (or equivalent), and will require atest flight after such work. Records ofall maintenance and repair work will be kept in a maintenance log for each aircraft.
c. All flight operations will be conducted by at least two individuals (PIC and observer) whowill maintain verbal communication capability with each other at all times duringthe flight, andwho will remain stationary on the ground duringtheflight operations: i. A Pilot In Command {PIC) who possess the following credentials: 1. An Airman Certificate issued under 14 CFR 61 (private pilot license) screened by the TSA 2. AThird Class medical certificate issued under 14 CFR 67. 3. A bi-annual flight review under 14 CFR 61.56 4. Successful completion ofa UAS knowledge test in aspecified form. 5. At least 200 cycles and 25 hours offlight experience in a UAS rotorcraft (orUAS fixed-wing in the case offixed-wing flight operations underthisexemption). Such cycles and hours may be gained duringflights underthis exemption ifa safe distance is maintained from persons in accordance with 14 CFR 91.119. 6. At least 5 hours offlight experience and 3 takeoffs and landings in makeand model being flown in the prior 90 days. Such cycles and hours may begained duringflights underthis exemption ifasafe distance is maintainedfrom persons in accordance with 14 CFR 91.119. ii. A Visual Observer. iii. A Sensor Operator as necessary. d. All flight operations will be conducted in accordance with valid Certificates ofAuthorization.
e. All flight operations will comply with the following: i. The manufacturers' user manuals. ii. Utilis Flight Operations and Procedures Manual {FOPM) and Aircraft FlightManuals (AFM) which include lost communication and other emergency and safetyprocedures. iii. Conducted in VMC conditions during daylight hours. iv. PIC and VO will maintain VLOS at all times.v. Pre-flight inspections (including ground control station, ifany) and safetyrisk assessments will be conducted priorto each flight. vi. Flight altitudes will remain below 400 feet above ground level. vii. Flight ground speeds will not exceed 50 knots. viii. Not intrude into Class B, CorD airspace, or published approach, SID orSTAR, ortake place within 5 nautical miles ofan airport. ix. Not be made near persons as required in 14 CFR 91.119 and not over persons onthe ground withouttheir prior permission.

x. Each flight will be logged in both the PIC's logbook and the aircraft logbook. xi. Not exceed 75% ofthe battery orfuel capacity ofthe aircraft, or 30 minutes,whichever
occurs first. xii. Any incidents will be reported within 24 hours ofoccurrence. xiii. Utilis Engineering, PA will maintain liability insurance ofat least $1,000,000 issued by amajor aviation insurance underwriter. xiv. Any applicable local FSDO requirements.

xv. All other applicable regulations concerned with the operation ofaircraft. f. Aircraft will use FCC compliant 2.4 GHz for command & control ofthe aircraft withwell-defined and tested lost link procedures.

Please advise us ofany additional information or changes that may be required.
Sincerely,



### Jon W. Owen- ChiefPilot EVP ofCorporate Development Utilis Engineering, PA