197 N Main St, Unit 3 Boscawen, NH 03303 www.BirdsEyeView.aero

Page 1 of 12 January 8 , 2016

From:

Adam Sloan

BirdsEyeView Aerobotics

To:

U.S. Department of Transportation, Docket Operations

Room W12

- 140 of the west building

Ground floor

1200 New Jersey Avenue, SE.

Washington, DC, 20590



## PETITION FOR EXEMPTION OF:

BirdsEyeView Aerobotics

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS PART 21, SUBPART H AND SECTIONS §§ 45.23(b), 61.113 (a) & (b), 91.7(a)

, 91.9(b)

, 91.103, 91.109, 91.119, 91.121, 91.151(a) & (b), 91.203(a) & (b), 91.405, 91.407(a) (1), 91.409(a) (2), 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF FIREFLY6 AND

QUANUM NOVA SMALL UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)



## Petition for Summary Grant

The FireFLY6 sUAS has been granted numerous previous petitions for exemptions by other companies and agencies. Therefore, BirdsEy eView Aerobotics wishes the Administrator to Summary Grant this petition. The FireFLY6 sUAS has been granted exemption in the following dockets:

 geoResource Technologies, Inc. Docket FAA

- 2015

- 0701

- 0003

 HAZON Solutions , Docket FAA

- 2015

- 0364

- 0001

 FlightWin k UAV Aviation , Docket FAA

- 2015

- 0781

- 0003

 Airmada Inc , Docket FAA

- 2015

- 7995

- 0001

 3D UAV Aerial Services , Docket FAA

- 2015

- 7067

- 0001

 GPS Development, LLC d/b/a SkyViewHD , Docket FAA

- 2015

- 0147

- 0003 t197 N Main St, Unit 3 Boscawen, NH 03303 www.BirdsEyeView.aero

Page 2 of 12 

## Contents

PETITION FOR EXEMPTION OF:

................................ ................................ ................................ ......... 1

Petition for Summary Grant

................................ ................................ ................................ .................... 1

GLOSSARY OF ABBREVIATIONS

................................ ................................ ................................ .... 3

SUMMARY

................................ ................................ ................................ ................................ ............ 4

INTRODUCTION AND INTERESTS OF THE PETITIONER

................................ ................................ .. 4

UNMANED AIRCRAFT SYSTEMS:

................................ ................................ ................................ ....... 5

FIRE FLY6

................................ ................................ ................................ ................................ .......... 5

QUANUM NOVA

................................ ................................ ................................ ................................ 5

BASIS FOR OUR PETITION

................................ ................................ ................................ ................. 6

CONDITIONS AND LIMITATIONS

................................ ................................ ................................ ......... 6

SECTIONS OF 14 C.F.R FROM WHICH BIRDSEYEVIEW AEROBOTICS SEEKS EXEMPTION

......... 8

14 C.F.R. (Format) Part 21 & Subpart H: Airworthiness certificates

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

14 C.F.R. 45.23(b): Marking of the aircraft

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

14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command

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

14 C.F.R. 91.7(a): Civil air craft airworthiness

................................ ................................ .................. 9

14 C.F.R. 91.9(b) (2): Civil aircraft flight manual, marking and placard requirements

...................... 9

14 CFR 91.103: Preflight action

................................ ................................ ................................ ...... 9

14 C.F.R. 91.109: Flight instruction

................................ ................................ ................................ . 9

14 C.F.R. 91.119: Minimum safe altitudes

................................ ................................ ...................... 9

14 C.F.R. 91.121: Altimeter Settings

................................ ................................ ............................. 10

14 C.F.R. 91.151(a): Fuel requirements for flight in VFR conditions

................................ .............. 10

14 C.F.R. 91.203(a) & (b): C arrying civil aircraft certification and registration

............................... 10

14 C.F.R. 91.405; 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance ins pections

......................... 10

PUBLIC INTEREST

................................ ................................ ................................ ............................. 11

EQUIVALENT LEVEL OF SAFETY

................................ ................................ ................................ ..... 11

PRIVACY

................................ ................................ ................................ ................................ ............. 11

NATIONAL SECURITY

................................ ................................ ................................ ........................ 11197 N Main St, Unit 3 Boscawen, NH 03303 www.BirdsEyeView.aero

Page 3 of 12 

### GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AIM Aeronautic Information Manual

ATO Air Traffic Organization

CFR Code of Federal Regulations

COA Certificate of Authorization

EO Electro

- Optical (TV Video)

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FPV First Person Video

GCS Ground Control Station

GPS Global Positioning System

HD High Definition

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot in Command

R/C Radio Control / Remote Contr oller

RTL Return To La unch

SAR Search and Rescue

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333

SO Safety Observer

sUAS Small Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Sight

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and Landing197 N Main St, Unit 3 Boscawen, NH 03303 www.BirdsEyeView.aero

Page 4 of 12 

## SUMMARY

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (The Reform Act), and 14 C.F.R. Part 11, BirdsEyeView Aerobotics, an sUAS developer and provider, hereby applies for an exemption from the FARs listed below to allow operation of sUAS commercially in airspace regulated by the FAA so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The requested exemption would permit BirdsEyeView Aeroboti cs to pursue its commercial interests in providing services to clients using sUAS in the following areas:

1. Training

2. Inspection

3. Surveillance

4. SAR



## INTRODUCTION AND INTERESTS OF THE PETITIONER

BirdsEyeView Aerobotics is an sUAS developer and provide r of safe, reliable unmanned aircraft for hobby, sport, and commercial applications in the form of the FireFLY6 VTOL Unmanned Aircraft System.

BirdsEyeView Aerobotics wishes to petition for exemption in order to conduct internal and customer

o perator t r aining, perform a erial d ata c ollection (mapping/agricultural), i nspection, s urveillance, and SAR operations . The FireFLY6 is designed to carry a variety of payloads such as Day EO , Thermal, HD Video, High Resolution Still, and Multispectral sensors

. The products of these sensors can then be used by clients to manage decisions pertaining their areas of responsibilities.

The Quanum Nova Quadcopter is to be used during initial operator train ing for mechanical and

software familiarization and proficiency prior to progressing to the FireFLY6 VTOL. The NOVA may also be employed by BirdsEyeView Aerobotics in small area data collection, photography, or sensor testing.197 N Main St, Unit 3 Boscawen, NH 03303 www.BirdsEyeView.aero

Page 5 of 12 

## UNMANED AIRCRAFT SYSTEM S :

FIREFLY6

BirdsEyeView Aerobotics seeks an exemption to operate the FireFLY6 Small Unmanned Aircraft for compensation or hire within the NAS. The FireFLY6 is a VTOL sUAS with a GCS. This s UAS provides

for vertical takeoff or landing in confined areas where traditional fixed wing flight is impractical or

unsafe. The aircraft is capable of transitioning between hover and forward

- flight modes aut omatically without extensive pilot experience or training. In addition, the system is capable of automatic or manual takeoff and landings, including automated RTL in the event a system failsafe event is triggered.

The FireFLY6 has a maximum gross weight of approximately 9 pounds, 95 cm in length, 152 cm of wingspan and a maximum speed of 50 knots

. The aircraft is propelled by six electric motors. The motors receive electrical power from two lithium polymer batteries

. T he FireFLY6 is constructed of frangible materials, mostly EPO Foam, light plywood, and plastics.



### QUANUM NOVA

BirdsEyeView Aerobotics seeks an exemption to operate the Quanum NOVA Sma ll Unmanned Aircraft for compensation or hire within the NAS. The NOVA is a four

- rotor miniature helicopter (QuadCopter) aircraft with GPS capability that is both flown via traditional R/C and/or GCS. The NOVA is 300mm X 300mm in size, weighs 875g (flying) , and has a typical flight endurance of 15 minutes. The NOVA contains an GPS based automatic flight controller capable of waypoint navigation and various pilot

- in

the

- loop modes.

Use of the NOVA QuadCopter is primarily to facilitate operator training on the FireFLY6 sUAS, and for

small

- area data collection and photography.197 N Main St, Unit 3 Boscawen, NH 03303 www.BirdsEyeView.aero

Page 6 of 12 

## BASIS FOR OUR PETITION

BirdsEyeView Aerobotics is petitioning for an exemption to operate FireFLY6 and NOVA aircraft using

various sensors and GPS

- enabled safety features. The s e sUAS are operated by a common GCS that provides instrumentation data of the aircraft and FPV. The GCS also visually depicts airspace within a

five

- mile radius of airports in order to provide the PIC situational awareness of local airspace

.

The FireFLY6 and NOVA have a failsafe function that is triggered in the event communicat ion is lost

between the aircraft and the R/C transmitter or GCS Data Link. At that time, the aircraft will return to its point of takeoff , transition to Hover Mode (in the case of the FireFLY6) , and land safely. If radio communication is restored, th e PIC is able to regain control of flight and land manually. Additionally, there is a failsafe function that triggers when the lithium

- polymer battery falls below an operator specified state of charge. In this case the aircraft will also return to its poin t of takeoff and land safely. The PIC can set a minimum state of charge in the battery failsafe to allow the drone sufficient energy to return from any phase of its mission.

Under the requested exemption, BirdsEyeView Aerobotics ensures all operators have completed sUAS education and training programs including all applicable reg ulations and guidance documents such as aeronautical background information including charts, NOTAM s and aircraft circulars, radio communications procedures, basic sUAS Aerodynamics, weather factors, and safe operations procedures.



## CONDITIONS AND LIMITATIONS

As the operator of these aircraft, BirdsEyeView Aerobotics is committed to the following conditions and limitations on its operations. BirdsEyeView Aerobotics understands that failure to comply will be grounds for the immediate suspension or rescission any exemption granted.

1. Operations are limited to the sUAS sta ted above when weighing less than 55 pounds including payload.

2. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per hour )

3. The aircraft will be operated at an altitude of no more than 400 feet (122 meters) AGL

unless under the allo wance of a Standard COA approved independently.

4. The aircraft will be operated within VLOS of the PIC or SO at all times. This requires the PIC to be able to use human vision unaided by any device other than corr ective lenses, as specified on the PIC’s or SO’s U.S. driver’s license.

5. All operating documents needed to operate the aircraft will be accessible during flight operations and made available to the administrator upon request. The operator will also present updated and revised documents if it petitions for extension or amendment.

6. Any aircraft that has undergone maintenance or alterations th at affect the aircraft operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight prior to conducting further operations.197 N Main St, Unit 3 Boscawen, NH 03303 www.BirdsEyeView.aero

Page 7 of 12 7. BirdsEyeView Aerobotics is responsible for maintaining and inspectin g the sUAS to ensure that it is in a condition for safe operation.

8. Prior to each flight, the PIC will conduct a pre

- flight inspection and determine the sUAS is in a condition for safe flight.

9. BirdsEyeView Aerobotics will follow all third

- party equipment ma nufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

10. The PIC will hold a sUAS flight training certificate and a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government.

11. BirdsEyeView Aerobotics will not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the sUAS in a manner consistent with how the

sUAS will be o perated to acquire aerial data, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). BirdsEyeView Aerobotics will operate flights for the purposes of training BirdsEyeView Aerobotics PICs and SOs (training, proficiency, and experience building) and determining the PIC’s ability to safely operate the sUAS.

12. The aircraft will not op erate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

- published

aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA.

13. The aircraft will 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 s tatute miles from the PIC

. 14. If the sUAS loses communications

, the aircraft will return to the takeoff location.

15. The PIC will abort the flight in the event of unpredicted obstacles or emergencies.

16. The PIC will be prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the aircraft to conduct the intended operation and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater.

17. All operations shall be conducted in accordance with an ATO

- issued COA if the blanket COA does not cover the intended operation.

18. Documents used by BirdsEyeView Aerobotics to ensure the safe operation and flight of the sUAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the GCS of the sUAS any time the aircraft is operating.

19. The aircraft will remain clear and give way to all manned aviation operations and

activities at all times.

20. The sUAS may be operated by the PIC from a moving device or vehicle; however, specific requests will be made via subsequent COA.

21. All flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structure s are present that sufficiently protect nonparticipating persons from the aircraft or debris in the event of an accident; or b. The owner/controller/operator of any vessels, vehicles or structures has granted permission for operating closer to those object s and the PIC has made an assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.197 N Main St, Unit 3 Boscawen, NH 03303 www.BirdsEyeView.aero

Page 8 of 12 22. The PIC, SO, operator trainees or essential persons will not be considered nonparticipating persons under this ex emption.

23. All operations conducted over private or controlled

- access property will be conducted with the permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

24. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA will be reported to the FAA's sUAS Integration Office (AF S −80) within 24 hours. Accidents shall be reported to the National Transportation Safety Board (NTSB) per instructions contained

on the NTSB Web site: www.ntsb.gov

.



## S ECTIONS OF 14 C.F.R FROM WHICH BIRDSEYEVIEW

AEROBOT ICS SEEKS EXEMPTION

14 C.F.R. (Format) Part 21 & Subpart H: Airworthiness certificates
Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203(a)(1). Given the size and limited operating area associated with the aircraft to be utilized by BirdsEyeView Aerobotics , an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 USC §447 01(f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed, will be at least as safe, or safer, than a conventi onal aircraft operating with an airworthiness certificate without the restrictions and conditions proposed.



### 14 C.F.R. 45.23(b): Marking of the aircraft
This regulation requires that certain experimental, provisionally certified aircraft, or light

- sport

ca tegory aircraft to be marked with letters between 2 inches and 6 inches high “limited”, “restricted,” “light

- sport,” “experimental,” or “provisional,” near each entrance to a cabin, cockpit or pilot station. Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAS, 2

- inch lettering may be impossible. BirdsEyeView Aerobotics will ma rk the sUAS as practicable.



### 14 C.F.R. 61.113(a) & (b): Private pilot privileges and limitations: Pilot in command
Sections 61.113(a) and (b) limit private pilots to non

- commercial operations. Because the sUAS will not carry a pilot or passengers, the prop osed operations can achieve the equivalent level of safety of current operations by requiring the pilot operating the aircraft to have completed a sUAS flight

- training course. Unlike a conventional aircraft that carries the pilot and passengers,

the sUAS i s remotely controlled. The area of operation is controlled and restricted, and all flights197 N Main St, Unit 3 Boscawen, NH 03303 www.BirdsEyeView.aero

Page 9 of 12 are planned and coordinated in advance. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial opera tions contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested exceeds the present level of safety achieved by 14 CFR 61.113(a) and (b).



### 14 C.F.R. 91.7(a): Civil aircraft airworthiness
The regulation requires that no person may operate a civil aircraft unless it is in airworthy

condition. As there will be no airworthiness certificate issued for the aircraft BirdsEyeView

Aerobotics contemplates operating, should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. Given the size of the aircraft , frangible construction, and the operational restrictions put on the aircraft, an equivalent level of safety will be provided.



### 14 C.F.R. 91.9(b) (2): Civi l aircraft flight manual, marking and placard requirements
The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capaci ty to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the Operating Manuals at the ground control point where the pilot flying the sUAS

will have immediate access to it.



### 14 CFR 91.103: Preflight action

This regulation requires the PIC take certain actions before each flight to ensure the safety of flight. An exemption is needed from this requirement, as the pilot will take separate preflight actions, including checking for weather conditions, checking flight battery or fuel requirements, checking takeoff and landing distances, and all other actions in the Operating Manual and safety checklists. These actions will provide an equivalent level of safety



### 14 C.F.R. 91.109: Flight instruction
Section 91.103 provid es that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. By design, sUAS do not have fully functional dual controls. Flight control is accomplished through the use of a GCS that communicates with the aircraft via radio communications. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to control the sUAS via radio signals from the controller is unaffected by the size and speed of the aircraft.



### 14 C.F.R. 91.119: Minimum safe altitudes
Section 91.119 establishes safe altitudes for operation of civil aircraft. The sUAS will never operate at altitude higher t han 400 AGL and all operations will occur during daylight hours under VMC only . The equivalent level of safety will be achieved given the size, weight and 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. Because advance notice to the property owner and any onsite personnel, as well as the precautions outlined below, all affected individuals will be aware of the planned flight operations. Flight operations will be conducted at least 500 feet from all non

participating persons (persons other than the P IC or SO), vessels, vehicles and structures,197 N Main St, Unit 3 Boscawen, NH 03303 www.BirdsEyeView.aero

Page 10 of 12 unless operations do not present an undue hazard. The sUAS will remain within visual line of sight of the PIC or SO. Flight operations will be conducted at least 5 miles from an airport. The PIC or SO will provi de notification to the local Flight Standards District Office and airport controller of all operations within 5 miles of an airport. The FAA will have advance notice of all operations through the filing of notices

- to

- airmen. Compared to flight operations w ith aircraft or rotorcraft weighing far more than the sUAS proposed herein, any risk associated with our operations is far less than those presently presented with helicopters and other conventional aircraft operating at or below 500 feet AGL. In addition, the low

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



### 14 C.F.R. 91.121: Altimeter Settings
This regulation requires each person opera ting the 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.” The sUAS will have a barometric altimeter, in

addition t o a GPS altitude read out. An equivalent level of safety will be achieved by the PIC confirming the altitude of the launch site shown on the GCS altitude indicator before flight and comparing the reading to its barometer reading

.



### 14 C.F.R. 91.151(a): Fuel requirements for flight in VFR conditions
Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Relief from Section 91.151(a)(1) is requested to the extent required to allow flights of sUAS during daylight

h ours in VFR conditions to continue until 90 percent of remaining battery power or fuel reserves

remain. BirdsEyeView Aerobotics seeks the requested relief because without an exemption from Section 91.151(a)(1), the flight time duration of the selected a ircraft will be reduced and severely constrain the practicality of any aerial acquisition of data that BirdsEyeView Aerobotics proposes to conduct pursuant to this Petition. The technical specifications of the proposed sUAS, their Operations Manuals, and B irdsEyeView Aerobotics’ proposed operating limitations,

ensure that BirdsEyeView Aerobotics will safely operate the selected aircraft during daylight

hours in VFR conditions until 90 percent of remaining battery power or fuel reserves remain.



### 14 C.F.R. 91.203(a) & (b): Carrying civil aircraft certification and registration
The sUAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. Therefore, there is no ability or place to carry certification and registration documents or t o display them on the sUAS. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS.



### 14 C.F.R. 91.405; 407 (a)(1); 409 (a)(2); 417 (a) & (b): Maintenance inspections
These regulations require that an aircraft 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 BirdsEyeView Aerobotics . Maintenance will be accomplished pursuant197 N Main St, Unit 3 Boscawen, NH 03303 www.BirdsEyeView.aero

Page 11 of 12 to the user guide or operating manual. An equivalent level of safety will be achieved because

these aircraft ar e limited in size and will carry a small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise, the sUAS can land immediately and will be operating from no higher than 400 feet AGL. The PIC will ensure that th e sUAS is in working order prior to initiating flight, perform required maintenance and keep a log of any maintenance performed. Moreover, the PIC is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condit ion to provide the equivalent level of safety

.



## PUBLIC INTEREST

Approval of exemptions allowing commercial operations of UASs for aerial acquisition of data enhances safety while reducing risk. Manned aircraft in certain application create a greater risk be cause the aircraft are much larger and carry an onboard human pilot. In contrast, a sUAS weighing 55 pounds or less will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. In addition, str eams of aerial data will allow large commercial entities to make decisions about how to best deploy ground resources and ensure the safety and cost

- effectiveness of their operations.



## EQUIVALENT LEVEL OF SAFETY

BirdsEyeView Aerobotics proposes that the exem ption requested herein apply to civil aircraft that have the characteristics and that operate within the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current and prop osed regulatory structure.



## PRIVACY

All flights will occur over private or controlled access property with the property owner’s prior consent and knowledge. Images or video taken of individuals will have consented to being filmed or otherwise they will be made anonymous.



## NATIONAL SECURITY

Given the small size of the sUAS involved and the restricted environment within which they will operate, our petition presents no national security issue. We respectively request exemption under Section 333

to enable Birds EyeView Aerobotics to operate efficient, limited, low

- risk commercial sUAS operations for the activities stated respecting at all times the space and privacy of citizens and property while keeping airspace safe.197 N Main St, Unit 3 Boscawen, NH 03303 www.BirdsEyeView.aero

Page 12 of 12 Hereby Submitted,



# Adam R. S loan

Adam R. Sloan

CEO BirdsEyeView Aerobotics 197 N Main St, Unit 3 Boscawen, NH 03303

Prepared by : 

# Erich J. Freymann

Erich J. Freymann Flight Technician BirdsEyeView Aerobotics