1
, September 11 , 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE Washington, DC 20590

RE: Petition for Exemption from Certain Federal Aviation Regulations according

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

Dear Sir or Madam:

ULC Robotics ( ULC ) is applying for an exemption from the Code of Federal

R egulations as detailed below

.

The exemption would permit commercial operation of small unmanned aircraft

system s ( s UAS) in the national air s pace (NAS) as regulated by the FAA for aerial data

collection to include, but not limited to the following uses:

I. Remote sensing and measuring by an instrument(s) aboard the s UA S including

A. imagery (photography, video, infrared, e tc.)

B. electronic measurement (precision inspection , RF analysis, etc.)

C. chemical measurement (particulate measurement, etc.)

D. or any other gathering of data by instruments aboard the sU A S

II. Assisting in maintaining public safety in times of emergency including

A. a erial photography and evaluation of emergency response scenes and operations with ULC agreement

B. aid in e mergency servi ces support and search and rescue with ULC

agreementULC Robotics 333 Petition 2 All operations performed by ULC are cost effective and protect the public by reducing
the size of the aircraft from one weighing up to several tons to one weighing less than 55 pounds. In addition, the UA does not use flammable liquid fuel. Instead, it operates on high

- energy batteries. The UA is flown in the low er strata of controlled and uncontrolled airspace, at 4 00 ft. AGL and below. ULC c ommercial operations will be performed according to FAA regulations or amended FAA regulations as permitted
under a Section 333 Grant of Exemption.

BACKGROUND AND REFERENCES

The US Department of Transportation Pipeline and Natural Hazardous Materials Administration estimates that there are approximately 2.5 million miles of pipeline transporting natural gas and other gases. Twenty

- five percent of the energy Americans

consume t ravels through these pipelines. Most of the consumption comes from home heating, requiring a highly complex distribution system utilizing more than 210 pipeline networks across the United States. These pipelines contribute more than two trillion
dollars to the American economy and provide more than nine million jobs.

Much of the pipeline infrastructure was built post World War II. Indeed, more than half of America’s natural gas transmission pipelines were installed before 1970. Every mile of
this network i s now susceptible to corrosion, both internal and external, fracturing, damage by outside parties, and tensile flaws. To mitigate the risk of environmental damage and enhance public safety, government regulation requires pipeline operators to continually a udit the safety and integrity of their pipeline infrastructure.

ULC Robotics works with energy and utility companies across the United States to solve infrastructure, technical, and operational challenges by developing and deploying technology which can e nable repair or inspection of hard

- to

- access infrastructure. ULC Robotics has a proven track record of delivering commercial

- level innovative technology that is used by utility and energy customers to provide: cost savings, efficiency and most importantly, improved safety to utility workers, contractors and the general public. Typically this is achieved by repairing gas leaks through trenchless robotic technology which creates a safer, gas

- free environment for the public. However gas leaks also occur above ground along protracted stretches of pipelines, in areas that are difficult to reach by road, high above the ground on the outside of buildings or utility structures, and ma ny other hard to access areas.

Traditional methods of pipeline inspection include slowly walking the entire distance of the main, which may prove problematic when the pipeline enters areas that are difficult to traverse. For hard to reach, overhead pipelines, expensive scaffolding is erected forULC Robotics 333 Petition 3 maintenance workers to scale while perfor ming gas leak inspection. This exposes the utility worker to the risk of falls. Both methods put the maintenance worker in close proximity to gas leaks, which may be severe enough to put the worker at risk of encountering a leak close to rupturing. However , without a long distance means of inspection to discover the problem area, the maintenance worker could walk into a hazardous situation without even realizing it.

ULC also works closely with a number of major utility companies to ensure the safety of

st ructural and electric infrastructure systems. In order to assess the integrity of these systems, maintenance workers may utilize helicopter surveys to scan electrical lines or buildings. Helicopters are costly and utilize highly flammable jet fuel that is its own hazard. In more closely confined urban areas this may not be practical, so maintenance workers must ascend electrical towers in order to perform inspections by hand. If there is a problem with one of the power lines themselves, a utility worker wil l don a special suit, creating a personal faraday cage, and traverse the lines, in order to assess where the damage may be. This type of utility inspection is necessary, though extremely dangerous due to the heightened risk of electrocution and falling.

Worker accidents, including falls, are a major concern when attempting to inspect utility systems in high rise locations and are a source of workplace fatality and injury on utility and construction sites. Utilizing sUAS for utility inspections would signif icantly reduce, if not eliminate workplace falls and accidents by reducing or eliminating the need for workers to carry out tasks at unsafe, risky heights. Employing sUAS in these situations
could save workers lives.

Utilities (water, electricity and gas) are essential services that play a vital role in economic and social development. Ensuring the safety and repair of the US utility systems are what ULC Robotics works to accomplish. Creating a sUAS utility assessment program with state of the art leak detection technology, cameras, and sensors would dramatically increase the safety of utility workers and customers by increasing the chance of locating gas leaks in these difficult to detect areas, decrease the risk of w orkers who would attempt to access these locations via scaffolding or high rising structures, and increasing the chance of repairing gas leaks before they r uptured or caused an explosion.

ULC wishes to increase its effectiveness with its clients and contr acting government agencies, increase the safety level of its employees and contracted workers on inspection sites and remain competitive economically by employing a UA during many of its operations. Therefo re, ULC is submitting this FMRA Section 333 E xempt ion petition.

In support of the petition and the FAA’s evaluation process, we reference previously granted 333 exemption petitions by the FAA with same or similar purposes as follows:ULC Robotics 333 Petition 4 • Aerial pipeline inspection: exemption no. 12105, X

- Cam Aerial

Solutions , Inc.

• Aerial digital imagery, survey, and inspection: exemption no 11992,

Aerial Check UAVs

• Further commercial purposes for safety and public awareness of UA uses; exemption no. 11409, Wade Bell

• Aerial photography and evaluation of emergency response scen es and operations: exemption no. 12508, Castle Rock Fire and Rescue Department

• Emergency services support and search and rescue exemption no. 12515, RPA/UAS Consulting LLC

DESCRIPTION OF PETITIONER For more than 15 years, ULC has imagined, designed and b uilt solutions to a wide range of pro blems for some of the most well known names in the energy industry. ULC develops unique solutions to energy industry technical challenges; from the creation of simple tools to complex electromechanical systems. Beginnin g with the conception of new ideas through redesigns of existing products to commercialization and full production builds, ULC provides a range of technical services that support the Utilities Industry’s needs.

NAME OF PETITIONER

Aubrey Anderson

ULC Robotics 88 Arkay Dr Hauppauge, NY 11788 Telephone: 631

- 667

- 9200

AGENT FOR PETITIONER

Mr. Brian Dyer

RPS

- West

Email: Brian.Dyer@RemotePilotSystems.com

ULC Robotics requests a Summary Grant of Exemption for the following aircraft:ULC Robotics 333 Petition 5 A

– Aibot X

- 6 approved under Exemption No 11356

B

– Yuneec Typhoon Q500 4K approved under Exemption No 11438

C

– DJI Inspire 1 approved under Exemption No 11204

D

– 3DR Solo approved under Exemption No 11832

Thank you for your time and attention..

Sincerel y ,

Brian DyerULC Robotics 333 Petition 6 DESCRIPTION OF UNMANNED AIRCRAFT SYSTEM S

ULC requests the following aircraft :

• t he Aibot X 6

• t he Yuneec Typhoon Q500

• the DJI Inspire 1

• the 3DR So l o

Aibot X6

The Aibot X6 is an electric multirotor aircraft configured as a vertical take

- off and landing hexacopter in a V

- 6 designed for aerial survey and inspection

. Aibotix in Germany has delivered more than 200 aircraft since 2011. The flight control system used

with the aircraft is designed and manufactured in Germany, has undergone continuous improvement and development , with all source code modules under company control.

Safety features include:

• Mitigation for loss of radio control link, through programmable emergency failsafe to controlled descent or, if GPS signal is sufficient, to return to point

of takeoff.

• The pilot may override waypoint programming with manual stick control in case of emergency or route adjustment.

• Telemetry is displayed on the pilot’s handheld controller and maybe announced by voice

.

• The X6 is optimized for aerial inspection with safety features to reduce pilot

workload , such as attitude stabilization, GPS satellite

- assisted navigation,

return to home and auto land.

The aircraft is slightly less than 4 ft. in diameter, is made of carbon

- fiber reinforced polymer in a high visibility color, with protective blade guards surrounding the six rotors, and is designed for a maximum takeoff weight of less than 15 pounds and a flight time of

about 20 minutes with its dual

- battery pow er. Maximum speed is about 55 mph , but treats this limitation as an emergency reserve, and plans no flying at greater than 25 mph

. The aircraft carries no flammable liquid fuel

.ULC Robotics 333 Petition 7 Radio control and video transmission systems meet FCC requirements for opera tion in the unlicensed spectrum of the 2.4 and 5.8 GHz ranges. Manufacturer warnings about interference from devices operating at or near these frequencies or their harmonics are

documented in the manufacturer’s manual

.

Safety features include:

• Mitigatio n for loss of radio control link, through programmable emergency failsafe to controlled descent or, if GPS signal is sufficient, to return to point

of takeoff.

• The pilot may override waypoint programming with manual stick control in case of emergency or ro ute adjustment.

• Telemetry is displayed on the pilot’s handheld controller and maybe announced by voice.

• The X6 is optimized for aerial inspection with safety features to reduce pilot workload, such as attitude stabilization, GPS satellite

- assisted navigation,

return to home and auto land.

Yuneec Typhoon Q500/Q500 +

The Typhoon Q500 series are vertical takeoff and landing unmanned aircraft of

qua dcopter design. Manufactured by Yuneec International Co. Ltd., the Typhoon Q500 has the world's first Smart Transmitter (the "ST

- 10 series Ground Station" with 10 channels) combining a 2.4GHz radio control transmitter with a 5.8GHz digital video link.

It o perates on a built

- in Android touch screen. Safety features include Geo Fencing, Home Mode and Return Home. Geo Fencing prohibits the aircraft from exceeding a programmed permitted radius. When activated, Home Mode will automatically return the

aircraft wi thin a 10

- foot radius of its starting point. Should the transmitter signal be lost or visual line of sight with the aircraft impaired, upon signal, Return Home will automatically take control of the aircraft and return it to the operator/base station.

Take off weight with manufacture provided camera and gimbal payload and battery is 3.75

lbs.

The Typhoon Q500 dimensions are 16.5 by 16.5 by 8.3 in. with a diagonal of 22.2 in. without rotor blades attached. It can fly up to 25 minutes on its 5400mAh 3S 11.1VULC Robotics 333 Petition 8 lithium polymer battery. Radio control and video transmission systems meet FCC requirements for operation in the unlicensed spectrum of 5.8 GHz ranges.

DJI Inspire 1

The Inspire 1 is a remote

- controlled, ultra

- light weight, vertical take

- off and landing unmanned quadcopter with a transportable ground station. It is manufactured by DJI,

which is headquartered in the Shenzhen, Guangdong province of China.

The Inspire 1 is equipped with an onboard computer stabilization controller and GPS. Syst em software allows the operator to monitor the flight’s performance via a smart phone or tablet providing them with a real time display of the altitude, battery life, GPS connections and camera view. In case of lost signal to the aircraft from the ground

s tation, the Inspire 1 includes non

- GPS safety features: Failsafe, Return Home and Dynamic Home Point to bring the flight to a safe conclusion.

The Inspire 1 weighs approximately 6 .4 lb. and is 22 in. by 22 in. by 8 in. The Inspire 1 uses carbon fiber and plastic components in its construction. The Inspire 1 also allows for geo

- fencing, letting the operator set safe altitude and distance limits for the flight.

The Inspire 1’s battery reports the voltage of each c ell, the total lifetime charges and discharges, and the overall health and battery status. Advanced algorithms calculate the distance of the aircraft and estimated time to return home, letting the operator know when to fly back. The low battery emergency p rocedure is triggered when the DJI smart battery is depleted to a point that may affect the safe return of the aircraft. The thresholds for these warnings are automatically determined based on the current aircraft altitude and its distance from the Home po int.

3DR Solo

The 3DR Solo is an electric motor, ultra

- light weight, vertical take

- off and landing

unmanned quadcopter. It uses the Pixhawk 2 autopilot system

— two 1 GHz

computers, one on the copter and one in the controller connected via a dedic ated W i

- Fi signal. Radio c ommunications are set a t 2.4 GHz. It has four brushless 880 kV motors onto which its propellers attach. Lithium polymer batteries power the motors

.ULC Robotics 333 Petition 9 The flight controller relies on GPS for navigational coordinates, plus uses data from

g

yros, accelerators, and other sensors to keep the aircraft safely flying. Solo has controlled, predetermined flight patterns generated from operator input. Its control system is also programmed for immediate safety with pause (stable hover) and “safety

net ” (limiting range and altitude) features. It comes preprogrammed to not exceed 150 ft. AGL. After landing or returning home, Solo will automatically detect the landing and stop the motors.

Standard flight time for the Solo without a payload is approxim ately 25 minutes. Maximum speed is listed in the user manual as 33 mph. The Solo weighs 3.3 lb. with a maximum payload of 1.0 lb. Its dimensions are 18 in. motor to motor, with propeller dimensions 10 in. with a diameter of 4.5 in. The propellers are const ructed with glass

reinforced nylon.

EXTENT OF RELIEF SOUGHT AND WHY

ULC asks for relief from regulations tabled below, which the authority of the FAA has previously granted in exemption certificates number 11062 along with six others

described as “in commonality ,” and in number 11109, which are for use of electric

rotorcraft. Th is incorporates the conditions and limitations of these grants of exemption, and in some cases imposes stricter limits on its own operations.ULC Robotics 333 Petition 10 CFR CODE CITATIONS

14 CFR

PART SUMMARY OF
REGULATION REASON FOR

EXEMPTION REQUEST EQUIVALENT LEVEL OF

SAFETY

61.113 (a) Private pilot privileges and limitations: pilot in

command Holder of private pilot certificate may not act as pilot in command (PIC) for compensation or hire.

Fl ying for compensation

on inspection missions is central to purpose of exemption request. Characteristics of aircraft, VLOS, under 400 ft. AGL, trained visual
observer in radio communication with pilot; remote site, construction industry safety protocols e nhanced by flight safety plan; PIC with airman’s certification, appropriate medical and vision qualification, currency
in the aircraft listed on the certificate, pilot training, testing, proficiency with similar and same model UA; and inspection/maintenanc e are defined in the and will ensure equivalent levels of safety.

61.113 (b) Private pilot privileges and

limitations: Pilot in

command Holder of private pilot certificate may act as PIC for compensation or hire if flight is incidental to business or employment and does not carry passengers for compensation or hire. Flying for compensation

on inspection missions is central to purpose of

ex emption request, not
incidental to business or employment. There is no passenger or pilot on
board the UA , thus safety issues are different from a manned flight.

ULC ’s aircraft have programmable automated safety features and emergency responses, have pre

flight checks for safety beyond commercial manned aircraft, can be geographically restricted by operator with programmable control points, have

communications with the PIC regarding fuel loss and other flight hazards. PIC will have ground school training c ertificate and additional 25 hours logged flight
time and 25 hours classroom and

field instruction as stated in

U FOM

.ULC Robotics 333 Petition 11 14 CFR

PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SAFETY

91.119 (c) Minimum safe

altitudes over other than congested

area Operating closer than 500 feet to a person, vehicle, or

structure may be necessary

for pipeline and equipment inspection. People will not be allowed over, under or within 500 feet laterally of the aircraft in flight. Some flights may require the participation or guidance of industry personnel, positioned as

close as 200 fee t. will brief them on safety and obtain necessary consent. Industry site safety rules

will be followed.

91.121 Altimeter settings Procedures to set and

confirm altitude do not provide for operation of remote telemetry to SUAS pilot. An onboard air pres sure sensor and software resolve height

differences as small as one
centimeter. Altitude is controlled by measuring air pressure and the

z

- axis accelerometer/GPS values. The starting point is a relative height measurement calculated by the flight controlle r. Altitude above ground is displayed on the pilot's handheld controller by telemetry, and alarms can signal

conditions of interest. 4 00 feet AGL is the maximum permissible

in the UFOM , which describes altimeter procedures.ULC Robotics 333 Petition 12 14 CFR

PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SAFETY

91.151 (b) Fuel requirements for flight in VFR
conditions Rotorcraft under VFR must carry enough fuel to reach first landing point

and then another 20

minutes. The multirotor aircraft specified in this petition is designed to fly

missions of 25 minute

durations. On aircraft specified , battery voltage under load is displayed on the pilot's handheld controller during flight. Battery chemistry does not support adequate current discharge below about 3 v per cell. Circuitry in the onboard flight controller measures voltage and

will start a failsafe procedure to

land before summed minimums
are reached. In the event that one or more cells fail, these minimums may be reached sooner than expected, due to rapid current drain against a smaller number of functioning cells. pilots are trained

to mo nitor voltage and recognize abnormal discharge in flight and

to land sooner than forced. If 20 minutes of flight time or 25% of reserve voltage under load is reached, pilot must commence landing.

91.405 (a) Maintenance required Required inspections and

d iscrepancies repaired
between the required inspections pertain to
certificated manned aircraft and procedures conducted by licensed maintenance personnel. In
the absence of certification requirements for SUAS
and SUAS maintenance personnel, reasonable

alte rnatives must be developed to maintain equivalent levels of safety. ULC will document maintenance, overhaul, replacement and inspection requirements in the
absence of manufacturer's requirements; will document and
maintain maintenance records and

technici an qualification criteria in

the UFOM

.ULC Robotics 333 Petition 13 14 CFR

PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SAFETY

91.405 (b) Maintenance
records Qualifications for maintenance personnel for
SUAS were not contemplated by these regulations, and a
reasonable alternative must be developed to maintain equivalent levels of safety. Qualifications, competence and testing for maintenance personnel
are defined in the UFOM

.

91.407 (a) (1) Operation after maintenance, preventive maintenance, rebuilding, or

alteration There is no authorization procedure for a person who can approve a return to service of an SUAS, and

a reasonable alternative must be developed to maintain equivalent levels of safety. Procedures for the PIC to test then approve a return to service

after maintenance are defined in

the UFOM

.

91.409 (a) (1) Inspections Annuals conducted by a qualified inspector require

authorization criteria for that inspector, not yet

defined for SUAS. A
reasonable alternative must be developed to maintain equivalent lev els of safety. Schedules for inspection and responsibilities of the PIC and qualified technician are described

in the UFOM

.

91.409 (a) (2) Inspections Issuance of airworthiness

certificates for SUAS under 55 pounds operated VLOS is not contemplated by these regulations Airworthiness is the responsibility

of the PIC and the technician as

defined in the UFOM

.ULC Robotics 333 Petition 14 14 CFR

PART SUMMARY OF
REGULATION REASON FOR
EXEMPTION REQUEST EQUIVALENT LEVEL OF

SAFETY

91.417 (a) Maintenance
records Regulations do not contemplate requirements or approval processes for

maintenance and inspection of
uncertificated SUAS,

however a reasonable
alternative must be developed to maintain equivalent levels of safety. The operator will maintain records according to the procedures specified in the UFOM

.

91.417 (b) Maintenance
records Retaining and transferring

records of maintenance and defects according to standards prescribed for

authorized maintenance and inspection is not contemplated in the regulations for SUAS. A
reasonable alternative is necessary to maintain equivalent levels o f safety. Records and documentation will be kept for all maintenance performed, defects, and for all components specified in the

UFOM

.

PILOT IN COMMAND AND CREW

The pilot in command (PIC) must hold an a ir man’s certification recognized by the FAA

such as an airline t ransport , commercial, private, recreational, sport pilot, or glider pilot (powered or non

- powered)

. The PIC must hold a current FAA airman medical certificate as required by the class of airman certification. In the case of the sport pilot certification,

the PIC must possess a valid U.S. driver’s license issued by a S tate, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC

must comply with the training and testing specified in the operator’s manual. The PIC

must remain in radio communication with a visual observer who complies with the training and test ing specified in the operator’s manual. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the P IC to be able to useULC Robotics 333 Petition 15 human vision unaided by any device other than corrective lenses, as specified on the

PIC’s FAA

- issued airman medical certificate or U.S. driver’s license

. The PIC must operate within visual line of sight only, and be able to see the at titude and orientation of the aircraft. If GPS or magnetometer is compromised, certain safety features may not operate, and the pilot must understand by training and experience how to recover control.

OPERATION OF THE UNMANNED AIRCRAFT

The aircraft will be under the operational control of the ULC Robotics designated PIC

.

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

1. Operations are limited to the UAS listed in the Appendix when weighing less than 55 pounds including payload.

2. Operations for the p urpose of closed

- set motion picture and television filming are not approved

.

3. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per hour). In no case will the aircraft be operated at airspeeds greater than the maximum

aircraft o perating airspeed recommended by the aircraft manufacturer.

4. The aircraft will be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The aircraft will be operated within visual line of s ight (VLOS) of the Pilot in Command (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 U.S.

driver’s license.

6. All operations will utilize a visual obser ver (VO). The aircraft will be operated within the visual line of sight (VLOS) of the PIC and VO at all times.

7. All operating documents needed to operate the UAS and will be accessible duringULC Robotics 333 Petition 16 UAS operations and made available to the Administrator upon r equest. The operator will also present updated and revised documents if it petitions for extension or

amendment.

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight prior to conducting further operations.

9. ULC is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

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

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

11. ULC will follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption will comply with all manufacturer safety bulletins.

13. The PIC will hold a UAS flight training certificate, in some cases training directly from the aircraft manufacturer, 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.

14. ULC will not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS w ill be operated 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 1 4 CFR § 61.51(b). ULC will operate flights for the purposes of training ULC PICs and VOs (training, proficiency, and experience building) and determining the PIC’s ability to safely operate the UAS.

15. UAS operations will not be conducted during night, a s defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions (VMC).

16. The aircraft will not operate within 5 nautical miles of an airport reference pointULC Robotics 333 Petition 17 (ARP) as denoted in the current FAA Airport/Facility Director y (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.

17. 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 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the aircraft will return

to a pre

- determined location.

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

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

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

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

22. All aircraft operated will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance

with 14 CFR part 45, Subpart C. Markings will be as large as practicable.

23. Documents used by ULC to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 will be available to the

PIC at the Ground Control Statio n of the UAS any time the aircraft is operating.

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

activities at all times.

25. The UAS may be operated by the PIC from a moving device or vehicle; however, specific requ ests will be made via subsequent COA.

26. All flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:ULC Robotics 333 Petition 18 a. Barriers or structures 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 objects 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.

27. The PIC, VO, operator trainees or essential persons will not be considered nonparticipating persons under this exemption.

28. All operations conduc ted 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.

29. 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 UAS Integration Office (AFS

− 80) within 24 hours. Acc idents must be reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Web site: www.ntsb.gov

BENEFIT TO THE PUBLIC

Approval of this petition allowing commercial operation s of an s UASs will enhance public safety by reducing public safety risk . The use of a b attery operated UA for aerial inspection, geo

- mapping and image and film capture, is more environmentally sound and

safe compared to a conventional

, liquid

- fueled aircra ft. It provide s a smaller

en vironmental footprint, d ecreases manpower and separate s the aircraft operators from

the air craft. The use of the specified s UA S s further protects the public by used in restricted environments and reducing impact hazards.

REASONS WHY THE EXEMPTION WOULD NOT ADVERSELY AFFECT

SAFETYULC Robotics 333 Petition 19 The inspection aircraft will be operated in accordance with ULC Robotic’s safety protocols

.

The inspection aircraft carries no person, cargo, or flammable liquid fuel. Its size and weight are a small fraction of any manned aircraft, and its safety systems reflect best design practices in the SUAS industry.

In addition, ULC Robotics will keep the approved Fli ght Manual at its ground control station. The PIC will have immediate access to it. Previous exemptions granted by the FAA concerning Section 91.9(b) establish that safety is not adversely affected when the approved Aircraft Flight Manual is kept at the gr ound control station of a S UAS, where it can be immediately accessed by the PIC.

When properly operated by trained pilots, a well

- designed s UAS and trained pilot can stay clear of people and property on the ground and in the air. Procedures, airmanship

sk ills, training and testing requirements for s UAS personnel will let the operator achieve safety levels in the NAS and on the ground that are equivalent to or great er than that in

manned aviation.

SUMMARY FOR PUBLICATION

The following summary may be pub lished in the Federal Register:

ULC requests an exemption from:

14 CFR Parts 61.113 (a) and (b) 14 CFR Parts 91.119 (c), 91.121, 91.151 (b), 91.405 (a) and (b), 91.407 (a) (1), 91.409 (a) (1), 91.409 (a) (2), 91.417 (a)

in order to operate a smal l unmanned aircraft system ( s UAS) for purposes of aerial inspections and monitoring, aerial geo

- mapping

, aerial imaging and filming

, aerial data

collection and public safety in times of emergency. The PIC will be appropriately qualified with a current FAA approved pilot certificate for s UAS operation and specialized training.

Imagery, electronic measurement, chemical measurement or any other gathering of data

to be done by instruments aboard the UA , a re conventionally done by manned aircraft operations, w hich use liquid fuel and weigh upwards of 5,000 lbs. These operations mustULC Robotics 333 Petition 20 fly the aircraft to and from the operation’s location. The use of the Aibot X6, the Yuneec Typhoon Q500 4K

, the DJI Inspire 1, and/or the 3DR Solo

— all of which weigh less

than 15 lbs. and are equipped electronic safet y features that minimize s the safety r isk to people and property compared to that of a manned aircraft

.

Flight operations outside the secure areas are not allowed. T here are no impacts to privacy.