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PJ Helicopters Inc. Attn: Seth Guns a uls 903 Langley Way Red Bluff, Ca. 96080 US Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington DC 20590

RE: Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Fed eral Aviation Regulations from : 14 CFR 61.3; 14 CFR 61.113(a) and (b); 14 CFR 91.7(a); 14 CFR 91.119(b) and (c); 14 CFR 91.121; 14 CFR 91.151 (a) (1) and (b) ; 14 CFR 91. 405(a); 14 CFR 91.407(a)(1); 14 CFR 91 .409(a)(1) and (2); 14 CFR 91.417(a) and (b)

To Whom It May Concern,

Pursuant to Section 333 of the FAA Moder nization and Reform Act of 2012, PJ Helicopters Inc. (referred to as Petitioner) , herby applies for and exemption from the listed Federal Aviation Regulations to allow operations of a commercial Unmanned Aircraft System (UAS). All proposed operations will be conducted under the conditions outlined in this petition or set forth by the FAA by Section 333.

**Ba ckground:** 

The Petitioner is a family

- owned world class precision helicopter lift service serving all industries nationwide since 1971. In the over 40 year history PJ Helicopters has maintained a flawless safety record with ultimate customer satisfaction. PJ Helicopters has extensive experience in the construction and patrolling of Utility Lines and Towers. We have filed this petition for exemption to operate a UAS for Utility Tower and Line Inspections. We currently perform this service in our helicopters. By switching to a UAS for this specific application the Petitioner feels we can provide a safer more efficient way of carrying out the Utility Inspections. The lightweight UAS greatly reduces the potential for harm of participating and nonparticipating individuals as well as property on and around the worksite location.2

**Unmanned Aircraft System:**
The Petitioner is proposing to use the Carbon Core Cortex Quadrocopter for th eir UAS operations. The Cortex airframe is made of carbon fiber and weighs less than 10 pounds, completely assembled. The overall diameter of the Cortex is 1,200mm. The UAS will feature dual flight control redundancy capable of 256 waypoints, auto fligh t, auto land, hover lock, and return home features. The Cortex will have the battery capacity for up to 30 minutes of uninterrupted flight

. The UAS will never be operated at a speed higher than 50 knots, and never higher than 400 ft. AGL. Before each flight the UAS will be updated with failsafe landing locations for the specific operation; should the link be lost during flight the UAS will return safely to the predetermined location and land. Given the size, speed of operation, lack of flammable and e xplosive liquids the Petitioner feels this would be a great asset to their operation and increase safety performance.

**UAS Operator** **:**
Each operator who will be in control of a UAS will undergo training and safety procedures of the UAS. Each operator wil l accumulate 25 hours of total time before operating the UAS in any commercial setting. The staff employed by the Petitioner already has extensive knowledge of airmanship and weather forecasts which will translate easily to UAS operations. Recurrent training will be held by the Petitioner in order to assure that qualifications and skills are being m et by all operators

. Before e ach flight of the UAS the operator will be responsible for checking weather conditions and determining that safe opera tions m ay be conducted. The operator will also be responsible for determining the airworthiness of the UAS by conduction preflight inspections per the Original Equipment Manufacturer recommendations. If the preflight inspection, reveals any condition that may a ffect safe operations, the UAS will be grounded until proper maintenance and repairs have been made. All maintenance and alterations will be documented in the aircraft records.
**Operating Parameters:**

The Petitioner has set forth th e following paramet ers for UAS operations. The UAS shal l always be inspected before conducting any operations. Only certified personnel with proper training may act as the UAS operator

. The operator must be designated before the beginning any flight operations and cannot transfer that designation for the3

duration of any flight. Visual Line of Sight must be ma intained at all times by the operator . The UAS will not be operated any faster than 50 knot s and shall n ever reach
an altitude higher than 400 ft. AGL. The UAS shall not fly in wind conditions any greater than 20mph. Flight operations will always be conducted under VFR conditions. UAS operations will be conducted over Utility Property, or Util ity Right of Way areas. The UAS will remain clear of and yield the right of way to all other manned vehicles.
The UAS will be integrated into the Petitioner’s existing Standard Operating Procedures and Safety Management System. By doing this the Petitioner is confident that it will be able to operate the UAS while being able to maintain or exceed current levels of safety.

**Public Interest:**
The Petitioner is requesting to operate a UAS for Utility Line and Tower inspections. This is a required task to ensure utility lines are in good condition and functioning properly. The Petitioner currently condu cts this task using a fleet of h elicopters. The introduction of a UAS will great ly reduce the risk of these operations. The UAS carries no flammab le fuel, or liquids that fixed

-wing or rotorcraft do. The UAV has no i nternal pilot or passengers so the potential for human injury is greatly reduced. The UAS is also significantly quieter that any fixed wing or rotorcraft airframe, reducing the public disturbance during operations. With the size, operational speed, and weight limits of the UAS it is reasonable to say that operations carried out by the Petitioner will be at least as safe if not safer than any convention al aircraft performing the same du ty.
**14 CFR 61.3 Requirements for Certificates, Ratings, and Authorizations 14 CFR**  **61.113(a) and (b) Private Pilot Privileges and Limitations: Pilot in Command**

The P etitioner asserts that since the UAS will not carry a ny pilot or passengers on board, the proposed operations will not adversely affect safety by requiring the operator in control of aircraft to have a pri vate pilot or a commercial pilot certificate, as long as they have knowledge of airmanship and possess the skills to operate the UAS

. In support of its position , the P etitioner argues that, since there are no standards for either private or commercial UAS pilot certificates, knowledge of airspace regulations and dexterity in the control and operation of the U AS acquired from actual operation of the aircraft will be the most important factors in establishing an equivalent level of safety. Through ground school and internal training the proper knowledge of airmanship can be achieved to maintain safe flight operations.4

Furthermore, the P etitioner explains that, given the restricted and controlled airspace within which operations will take place, t he key factors needed by the operator are knowledge of the airspace within which the operation will take place and how that airspace fits into the Natio nal Airspace System (NAS). The P etitioner also states t hat it cannot be assumed that a private pilot or commercia l pilot, approved to operate a rotorcraft or fixed wing aircraft, has the skill or ability to safely opera te an unmanned aerial system , operating at 400 ft. AGL or lower, within strictly control led pre

- approved airspace.
The Petitioner is confident that with the proper training and safety measures put in place it can effectively carryout it’s proposed operations. Hands

- on experience with the UAS is a far more effective guarantee of flight safety than a private pilot or commercial pilot certificate would be, until the FAA Pilot Certificate requirements catch up to the UAS technology.
The risks associated with the operation of the UAS (given its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of risk associated with private pilot operations or commercial operations contemplated by Pa rt 61 with conventional aircraft (fixed wing or rotorcraft), that allowing operations of the UAS as set forth in this petition meets or exceeds the present level of safety

. It is unfeasible to state that a pilot with a certification (private or commercial ) would be able to operate the UAS to a higher level of safety than a person who does not hold any pilot certificate, provided they have proper knowledge of a irmanship, and are familiar with the UAS he or she is operating. Currently there is no training i ncluded in private pilot or commercial pilot certification process regarding UAS operations. A n equivalent level of safety will be provided by allowing operation of the UAS without a private pilot’s certificate or a commercial pilot’s certificate, under t he conditions set forth herein.

**14 CFR 91.7(a) Civil Aircraft Airworthiness**
The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Since there is no regulatory standard for determining airworthiness of a UAS, there will be no certificate i ssued

. Therefore at this time regulation 91.7(a) is not applicable for UAS operations and an exemption is needed

. However, t he Petitioner will follow all safety and inspection proce dures outlined by the5

Original Equipment Manufacturer (OEM) to determine airworthiness. The operator will determine the airworthiness of the UAS by conducting prefli ght and post flight insp ections. If at any time the operator determines the UAS not be airworthy it is to be grounded im mediately until all proper repairs have been made. The UAS will undergo a test flight after any such repairs to ensure functionality before it is return ed to commercial operations.
**14 CFR 91.119(b) and (c) Minimum Safe Altitudes**

The Petitioner’ s request ed relief from14 CFR 91.119(b) and 14 CFR 91.119( c ) , as there will be times when the UAS will operate over congested area’s to in spect utility towers or lines located on Utility Land or Utility Right of Way. Exemption from 91.119(b) will be needed to conduct operations. The regulation states, “Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 ft. above the highest obstacle within a horizon tal radius of 2,000 ft. of the aircraft.” With the UAS having an operation ceiling of 400 ft. 91.119(b) is not applicable for the Petitioner to conduct its proposed operations in compliance of this regulation . For the Petitioner working over congested areas is very common practice . The Petitioner is very aware of the consideration that is needed to safety during these types of operations. The operator will make a safety assessment of the risk of the operation under the proposed conditions and will deter mine that it does not present an undue hazard before flight operations are to begin

. Prior to conducting UAS operations, all persons not essential to flight operations (nonparticipating persons) must remain at appropriate safe distances.

The Petitioner n otes that because it requests to operate at altitudes only up to 400 ft. AGL, an exemption is n eeded from 14 CFR 91.11 9(c) to allow for such operations. As discussed in Exemption No. 11109 to Clayco, Inc. (Docket No. FAA

- 2014

-0507), operations conducted closer than 500 feet to the ground may require that the UAS to be operated closer than 500 feet to essential persons, or objects that would not be possible without additional relief. Operations will always be conducted in an authorized, controlled area. Due to the specific operation proposed the UAS will at times b e closer than 500 ft. to the operator, essential people , vehicles, and structures therefore exemption is needed from 91.119(c).
The Petitioner is confident that since it currently carries out t he operations described in this document with rotorcraft, it will be able to at least maintain or exceed current safety levels by utilizing a UAS.6

**14 CFR 91.121 Altimeter Settings**

The P etitioner is a lso requesting an exemptio n from regulation 91.121, as the UAS will have a GPS altitude readout instead of a barometric altimeter required by the regulation. The P etitioner and operator will achieve an equivalent level of safety via live flight data and preflight safety checklist set forth by OEM

. The operator will confirm the altitude of the launch site shown on the GPS altitude indicator be fore flight in order to ensure accuracy.
**14 CFR 91.151(a) (1)**  **and (b) Fuel Requirements for flight in VFR Conditions** 
This regulation prohibits any person from beginning a flight in a fixed

-wing aircraft under VFR conditions (with consideration of wind and forecast weather conditions) unless there is enough fuel to fly to the first point of intended landing and, assuming normal cruise speed

– (1) During the day, to fly after that for at least another 30 minutes. Part B of this regulation describes operation requirements for rotorcraft.
The UAS has a battery that provides up to 30 minutes of powered flight . I n order to comply with this regulation flight times wou ld have to be limited to 10 minutes before the UAS would need to be grounded in order to maintain proper battery reserve as described in part 91.151. This limited flight time is not feasible and would make operations nearly, if not completely impossible. All operations will be conducted with a fully charged battery. Flight time will be limited to 30 minutes or when 25% battery life remains; whichever is to occur first. The operator will be able to monitor battery percentage th o rough their flight control s. With the operator maintaining VLOS and with 25% battery remaining, there will be still be sufficient time to return the UAS to the pla nned operatio nal landing zone. Therefore, the regulation is not applicable to the UAS, however the Petitioner will ma intain its own safety standard as stated above.
**14 CFR 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) and (b) Maintenance**  **Inspections and Records**
The Petitioner is also requesting relief from maintenance and inspection requirements under 91.405(a) and (b), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a). A n exemption should be granted under these sections because the UAS to be used is not a U.S. registered civil aircraft with an airworthiness certificate and therefore 14 CFR 917

regulati ons do not apply. Furthermore a designated official certified by the FAA to have maintenance si gnature authority does not currently exist for UAS operations . However, the Petitioner will employ a maintenance and quality assurance program which meets
or exc eeds applicable regulatory standards for U.S. registered aircraft. No operations will take place without inspections and maintenance items being completed. All inspections and maintenance action items will be documented in aircraft logs. The P etitioner fu rther states that Original Equipment Manufacturer (OEM) requirements will be followed in the performance of maintenance, inspection and record keeping for the UAS.
The Petitioner states that the OEM defines the maintenance requirements for the unmanned ai rcraft and per those requirements, the Petitioner will ensure that it will conduct all inspections to precise OEM standards. Again, n o flight operations will take place without required inspections and maintenance items being completed. Further, all inspections and maintenance action items will be documented in aircraft logs. The Petitioner will comply with the manufacturer's UAS component, maintenance, overhaul, replacement, inspection, and life limit requirements. The operator is responsible for a through preflight and post flight inspection of the UAS to ensure airworthiness. The inspection shall be conducted in accordance with the instructions outlined in the manufactures user’ s manual. When necessary o nly qualified OEM mai ntainers will perform higher level inspections and mai ntenance or overhaul per OEM standards.

**Review of Regulations seeking exemption from:**

**14 CFR 61.3 14 CFR 61.113(a) and (b)**  **14 CFR 91.7(a) 14 CFR 91.119(b) and (c)**  **14 CFR 91.121 14 CFR 91.151(a)(1)**  **and (b) 14 CFR 91.405(a)**  **14 CFR 91.407(a)(1)**  **14 CFR 91.409(a)(1) and (2) 14 CFR 91.417(a) and (b)** 8

**Petitioner Closing Statement**
The Petitioner feels that with a grant of exemption it will be able to carry out Utility Inspections with a new level of unprecedented safety. Inspections are inherently dangerous, but with the attention to detail and safety procedures already put in place the Petitioner has been able provide excellent service year after year to its customers. Safety has always been a high priority here, and with a great SMS in place we strive hard to asses any potenti al risks or hazards and reduce the chance of injury or damage to any persons or property. Due to the size, weight, operational speed, and lack of flammable fuels in the UAS t he potential for injury or damage is greatly reduced. This our ultimate goal, to provide a more efficient and safer operation. We invite you to please look at our website, www.pjhelicopters.com for further information regarding our company’s operations.