Page 1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION DOCKET MANAGEMENT SYSTEM 1200 NEWJERSEY AVE., SE WASHINGTON, DC 20590
**IN THE M AT** **TER OF THE PETITION FOR EXEMPTION OF:**



## RoboFlicks, LLC

**FOR A N EXEMPTION SEEKING REL** **IEF FROM THE REQUIREMENTS OF**  **THE FAA REFORM A** **CT AND PA** **RT 11 OF THE FEDER AL** **A VIA**  **TION REGULA**

**TI ONS FROM**  **TI TLE 14 OF THE CODE OF FEDERA** **L REGUL AT** **IONS SECTIONS**  **C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a);**

**91.405 (a); 91.407(a) (1); 9 1.409 (a) (2); 91.417 (a) & (b).**  **CONCERNING COMMERCIA L OPERA**  **TION OF UNM AN** **NED AIR** **CRA FT SYSTEMS**  **PURSUA NT TO SECTION 333 OF**  **THE F AA M** **ODERNIZA TION**  **AN D REFORM A** **CT OF 2012 (PUBLIC L AW** **112 -** **95)**

Submitted	onAugust	31,	2015 RoboFlicks,	LLC 413	S.	Portland	St. Bancroft,	IA	50517 Brad	BolligPage 2



## GL**OSSARY OF ABBREVIA TIONS** 

AGL Above	Ground	Level AOI Area	of	Interest ATC Air	Traffic	Control ATO Air	Traffic	Organization AV Aerial	Vehicle CFR Code	of	Federal	Regulations COA Certificate	of	Authorization FAA Federal	Aviation	Administration FAR Federal	Aviation	Regulation GCS Ground	Control	Station GPS Global	Positioning	System LOL Loss	of	Link NAS National	Airspace	System NOTAM Notice	To	Airman PIC Pilot	In	Command Section	333 FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	Section	333 SO Safety	Observer SOP Standard	Operating	Procedures sUAS Small	Unmanned	Aircraft	System sUAV Small	Unmanned	Aircraft	Vehicle UA Unmanned	Aircraft UAS Unmanned	Aircraft	System UAV Unmanned	Aircraft	Vehicle VFR Visual	Flight	Rules VLOS Visual	Line	of	Site VMC Visual	Meteorological	Conditions VTOL Vertical	Take

-Off	and	LandingPage 3



## INTRODU**CTION AND INTERESTS OF THE PETITIONER**

Dear	Sir	or	Madam:
Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, RoboFlicks, LLC, Operator of Small Unmanned Aircraft Systems (“sUASs”) equipped to offer on-demand commercial UAS operations for a host of industries and applications and to perform the purposes listed below, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUAV’s/UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established bythe FAA in an exemption granted under either Section 333 or Section	49	U.S.C.	§44701(f)
As described more fully below, the requested exemption would permit the operation of a UAS under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide safety enhancements in the fields in which it will operate, which now depend upon conventional aircraft or humans climbing high on dangerous structures, walking in insect laden swamps, and working adjacent to treacherous infrastructure. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities	to	“... establish requirements	for	the	safe	operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform	Act.1Page4



## Ex**ecutive Summary** 

**Expeditious Summary Grant Approval Request**

The petitioner requests the agency issue a summary grant process for this application as the	FAAhas	already	granted	a	previous	exemption	similar	or	identical to	each	and	every	request,	herein.


### Description of**Type, Make and Models of sUAV/UAS Requested:**

The petitioner is seeking an exemption to commercially operate sUAV’s makes and modes	as	follows: DJI Inspire	1, DJI

– Spreading	Wings S1000
Each separately weighs 55 lbs. or less, with imaging payload and applicable equipment. Equipment operation manuals for each sUAV are included for your reference and are considered confidential information for each respective company’s UAS and are affixed	separately	inthese	documents labeledAppendix

. 

### Commercial (Mission, Operation) Purpose:

RoboFlicks proposes the use of the sUAV’s will be for capture of high resolution imagery and video of residential or commercial Real estate, Photography , Videography/Filmaking, Precision agriculture, Industrial/Safety inspections, Insurance, Education/Academic research, Search and Rescue, Police and Fire benefits, and	Survey/Mapping/GIS

. This exemption request, once granted would allow the petitioner to operate a small unmanned	aerial	vehicle	(sUAV),	unmanned	aircraft	system	(UAS)	to	conduct	bridge Inspections, flare stack inspection, utility

-power generation system inspections and patrolling, aerial inspection, photography and videography of residential and commercial real estate, weddings, aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, close set filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, Aerial imaging for safety, monitoring and comparing work efforts andPage 5

completion percentages, and security of controlled environment of various sites, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools. colleges, professional sports, open air events and fairs, research, risk management and assessment, motion picture production, surface mining, closed set filming2, disaster	and	catastrophe	events. 

### Regulations from which the E**xemption Relief is requested** **:** 14	C.F.R.	§	61.113	(a)	&	(b) 14	C.F.R.	§	61.133(a) 14	C.F.R.	§	91.7(a) 14	C.F.	R.§ 91.119 14	C.F.R.	§	91.121 14	C.F.R.	§	91.151	(a) 14	C.F.R.	§	91.405	(a) 14	C.F.R.	§	407	(a)	(1) 14	C.F.R.	§	409	(a)	(2) 14	C.F.R.	§	417	(a)	&	(b)



### Commitment to Safety

As part of its commitment to safety and innovation, RoboFlicks is asking for this exemption in	part, to reducethe risk ofinjuryto its employees and contractorswho participate in the proposed activities the petitioner requests, including but not limited to damage to agriculture, natural habitat, buildings and other structures within	theUnited States.


### Expertise & Experience Founded by Brad Bollig, an innovative and creative individual with past FAA Air Traffic Control Experience as well as RC Aircraft experience and member of the Academy of Model Aeronautics (AMA). As (PIC), I’m extremely well trained in FAA safety operations, airspace operations, as well as the future of FAA Air Traffic Control,	NextGen.
RoboFlicks has been operating its lightweight sUAS around the Midwest at numerous sites without incident

. Roboflicks has proven its ability time and timePage 6

again to carry high definition film quality cameras safely and effectively in a variety of demanding and sensitive situations. I, Brad Bollig, founder of RoboFlicks LLC would like to formally request permission to fly its sUAS’s commercially in the United States. Each flight will and always has consisted of at least two dedicated individuals,	the	pilot	and	spotter. 

## The Ex**emp tion Request** 

RoboFlicks proposes the use of the sUAV’s will be for capture of high resolution imagery and video of residential or commercial Real estate, Photography, Videography/Filmaking, Precision agriculture, industrial/Safety inspections, Insurance, Education/Academic research, Search and Rescue, Police and Fire benefits,	and	Survey/Mapping/GIS
The imagery and video will be used to identify the condition of landscapes, agriculture, events, disasters and infrastructure to conduct bridge inspections, flare stack inspection, utility

-power generation system inspections and patrolling, aerial inspection, photography and videography ofresidential and commercial real estate, weddings, aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial imaging for safety, monitoring and comparing work efforts and completion percentages, and security ofcontrolled environment ofvarious sites, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools, colleges, professional sports, open air events and fairs research, risk management and assessment, motion picture production,	surface	mining,	closed	set	filming,	disaster	and	catastrophe	events.
The UAS will be operated by RoboFlicks. Given the small size of the sUAV’s involved, no more than 55 lbs., majority ofthe speed of operation be between 5

-15 mph and the restricted environment within which they will operate, the Petitioner falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that	the	FAA	must,	by	exemption,	allow	commercial	operations of	UASs	to	commence immediately.
This exemption application is submitted to fulfill Congress’ express goal in passing Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems mayPage 7

operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	national security in	light	of	the	following:

 The	UAS’ size,	weight,	speed,	and	operational	capability;

 Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas;	and

 Operation	of	the	UAS	within	visual	line	of	sight	of	the	Operator.
Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements	for	the	safe operation	of	such	aircraft	in	the	national	airspace	system.” Id.	§333(c)	(emphasis	added).3

RoboFlicks in filing this application is requesting that the FAA combine the grant of the Section 333 exemption with a standard Certificate of Operation (COA) that will allow commercial operations of its RoboFlicks’ sUAV without the necessity offiling for a COA for each flight, unless such flight is to be conducted in an area not approved in the exemption. Compliance with the conditions agreed to herein and that may be imposed by the FAA, as set forth in prior Section 333 exemptions, provide	the	separation	needed	from	other	aircraft.
In addition, given that all operations will be conducted below 400 AGL feet and no closer than 5 nautical miles ofthe geographic center of an airport as denoted on a current FAA published aeronautical chart, unless a letter of agreement with that airport’s management is obtained, RoboFlicks requests that operations over congested or densely populated areas be allowed

. Such operations will only be under

-taken with the approval ofthe land or home owner, as set forth herein, and will comply with the requirements that operations be no closer than 500 feet to the adjacent building unless the land owner has provided permission, and the Operator has	made	a	safety	assessment	ofthe	risk	from	such	operations.



### Operator Requirements

RoboFlicks sole (PIC) is currently receiving training for his Sport

-Pilot License. As well	as	receiving	his	Sport

-Pilot	license	in	a	few	weeks,	RoboFlicks	(PIC)	has	FAA	AirPage 8

Traffic Control Experience as well as a current Air Traffic Control Tower Operator Written	Test	license and	Third	Class	Medical.
Advanced sUAV’s have a navigation and control system and auto
-pilot that allows it to execute very accurate pre-programed flights. Flights are pre-programmed with GPS waypoint to establish perimeters beyond which the aircraft will not operate. Flights under auto
-pilot are not directed by positive manual input, but through preprogrammed flight parameters that are executed by the auto
-pilot. In the case of unplanned	events,	the	Operator	inputs	preprogrammed evasive	maneuvers	from	the control unit, and the autopilot executes those maneuvers. Pre

-programmed Operator interventions include: initiation ofholding at present position; suspension of mission; fly back to launch point; abort mission and land immediately; and emergency power cut off and land (flight termination system). Additional automated safety functions and safety enhancing features of the Advanced sUAV’s mayinclude	the	following: 1) Auto

-pilot detection of lost GPS or of insufficient satellites initiates an immediate landing, 2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. Low	power	beyond	10%	triggers	an	immediate	landing, 3) Ifthe auto
-pilot detects a lost

-linktothe ground controller, the UASwill hold position at its current location for 5 seconds and ifthe signal is not restored, execute	a	return to	home	and	land, 4) Redundant “kill switches” that enable completely shutting the aircraft down in	flight	in the	event	of	a	loss	of	control	or	un

-commanded deviation	from	the flight	path, 5) The	aircraft,	weighs less	than	14lbs.,	fully	loaded, 6) The	motors	are	driven	by	pulse	width	modulated	signals,	not	analog	signals, 7) The aircraft will operate for the Purposes at no more than 15 mph (while imaging) nor above 200 feet above the structure (imaging altitude) or a maximum	of	400	feetAGL.

A	handheld	radio	controller	controls	the	sUAVand	the	vehicle	is	operated	within	the line of sight. The requirements of Part 61.127 (commercial flight proficiency) and §61.107 (private flight proficiency), to the extent they are relevant to UAS operations, can be taught in the training proposed herein. As a review of the requirements of part 61.127 and 107 demonstrate, the issues presented as they relate to a 12 pound aircraft, operating at less than 5 knots during filming operations are those taught in ground school and in flight training with the particular UAS and not gained from accumulating flight hours in a fixed wing or rotorcraft gas or jet A powered aircraft completing cross country flights and take offs	and	landings	at	controlled	and	uncontrolled	airports. The	Operatorwill	be	operating	the	aircraft,	always	within	line	of	sight.	He	or	she	will walk and follow the aircraft around the inspection area so that while it is flying it’sPage 9

pre-programed and at times, manual flight path, the UAS will always be directly in his or her line of sight. The Operator will not be distracted by viewing the pictures taken during the flight. Rather, once the sUAV is launched, the Operator’s only duty will be to watch the flight of the UAS over the structure and intervene to address flight path deviations or other issues that arise during the flight. The functions that an observer performs where the aircraft is flown at long distances from the launch areawill notbe necessary asthe Operator will always havethe aircraft in his or her direct sight. The observer also will not be necessary because the Operator will conduct a pre-flight inspection of the area, will and if needed, cordon off the area and	will	perform	frequent	visual	scans	of	the	area	while	the	vehicle	is	operating.



### Ai **rcraft and Equivalent Level of Safety**

The Petitioner proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level ofsafety to operations underthe current regulatory structure because the proposed operations represent a safety enhancement to the operations conducted with conventional aircraft or with humans climbing up and around structures. These conditions are drawn	from	Exemptions	11136,	11138,	11172,	and	11174
These limitations and conditions to which RoboFlicks (referred to as “Operator”) agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1) Operations authorized by this grant of exemption are limited to the	aircraft described in	the	Operator’s manual,	which	is	a	multi

rotor weighing up to 55 pounds: Proposed operations of any other aircraft will require a new petition or a petition to amend this	grant. 2) The UA may not be flown at an indicated airspeed exceeding 15 mph (5mph during	inspections). 3) The UA mustbe operated at an altitude ofno	morethan 400 feet above ground level (AGL), as indicated by the procedures specified in the Operator’s manual. All altitudes reported to ATC must	be	in	feet	AGL. 4) The	UA	must	be	operated	within	visual	line	of	sight	(VLOS)	of	the Aircraft Operator	at	all	times.	This	requires	the	Aircraft Operator to be able to use human vision unaided by any device otherthanPage 10 corrective lenses, as specified on the Operator’s FAA

-issued airman	medical	certificate. 5) The	Exemption	Holder’s	Manuals	must	be	amended	to	include	all conditions and limitations required by the FAA. The Manuals must be maintained and made available to the Administrator upon	request.	If	a	discrepancy	exists	between	the conditions	and limitations in the exemption and the procedures outlined in the Exemption Holder’s Operator’s manual, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, the Aircraft Operator must follow the procedures as outlined in its Aircraft’s manual. The Exemption Holder may update or revise its Manuals. It is the Exemption Holder’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The Exemption Holder must also present updated and revised documents ifit petitions for an extension or amendment ofthis exemption. Ifthe Exemption Holder determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the Exemption Holder must petition	for	amendment	to	its exemption. 6) Prior	to	each	flight,	the	Aircraft	Operator	must	inspect	the	UAS	to ensure it is in a condition for safe flight. Ifthe inspection reveals a	condition	that	affects	the	safe operation	of	the	UAS,	the	aircraft is prohibited from operating until the necessary maintenance has	been	performed,	and	the	UAS	is	found	to	be	in	a	condition	for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly	documented	in	the aircraft	records. 7) Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight in accordance with the Exemption holder’s Manuals. TheAircraft Operator who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the Exemption Holder’s	Operator’s	manual. 8) The Exemption Holder must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention to flight critical components that may not be addressed in the manufacturer’s	manuals.Page 11 9) The Exemption Holder must carry out its maintenance, inspections, and record keeping requirements in accordance with the Operator’s Manuals. Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight	hours,	description	of	work	accomplished,	and	the	signature of	the authorized	technician	returning	the	UAS	to	service. 10) The authorized technicians must receive and document training referenced	in	the Exemption Holder’s	Manuals. 11) Each UAS operated under this exemption must comply with all manufacturer System	and	Safety	Bulletins. 12) The Exemption Holder’s maintenance personnel must make a record entry in the UAS logbook or equivalent document of the corrective action taken against discrepancies discovered between	inspections. 13) Prior	to	commencing	operations,	the	Aircraft	Operator	shall	have logged at least 25 hours oftotal time as a UA rotorcraft pilot and at	least	ten	hours	logged	as	a UA pilot	with	a	similar	UA	type and 5	hours	in	the	make	and	model. 14) If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the private or controlled

-access property and land or be recovered in accordance	with	the	Exemption	Holder’s Manuals. 15) The Aircraft Operator must abort the flight in the event of unpredicted obstacles or emergencies, including unauthorized people entering the flight area, in accordance with the Exemption	Holder’s	Manuals. 16) The Aircraft Operator is prohibited from beginning a UAS flight unless (consideringwind	and	forecast	weather conditions)	there is enough power to fly to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 10 minutes. 17) All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordancewith 14 CFR part 45, Subpart C. Markings mustbe as large	as	practicable. 18) Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with thePage 12 Federal Communications Commission (FCC) or other appropriate	governmentoversight	agency	requirements. 19) The documents required under 14 CFR 91.9 and 91.203 must be available to the Operator at the Ground Control Station of the UAS	any	time	the	aircraft	is operating.	These	documents	must	be made available to the Administrator or any law enforcement official	upon	request. 20) The UA must remain clear and yield the right ofway to all other manned operations and activities at all times (including, but not limited to, ultra

-light vehicles, parachute activities, parasailing activities,	hang	gliders,	etc.). 21) The UA may not be operated by the Aircraft Operator from any moving	device	orvehicle. 22) UAS	operations	may	not	be	conducted	during	night,	as	defined	in 14	CFR	1.1. 23) All operations must be conducted under visual meteorological conditions (VMC). The UA may 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 Operator. 24) During operations the UA may not operate within 5 nautical miles of the geographic center of an airport as denoted on a current FAA

-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM, if as required	by	the	Operator’s	COA.	The	letter	of	agreement	with	the airport management must be made available to the Administrator	upon	request. 25) The UAS may not be operated over congested or densely populated	areas	unless the	conditions	set	for	in	#26	are	satisfied. These populated areas include but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or TerminalArea Charts (TAC). However, aeronautical charts may not reflect pertinent local information. Ultimately, it is the Operator’s responsibility to maintain the minimum safe altitudes required by § 91.119 (d) (1). 26) Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:Page 13 a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the event of an accident. The Aircraft Operator must ensure that nonparticipating	persons	remain under	such	protection.	If	a situation arises where nonparticipating persons leave such protection and are within 30 feet of the UA, flight operations	must	cease immediately	and/or; b. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted permission and/or the Aircraft Operator has made a safety assessment of	the	risk	ofoperating	closer	to	those	objects	and;

c. Operations near the Aircraft Operator do not present an undue	hazardto	the	Operator	per	§	91.119(a). 27) All operations shall be conducted over private or controlled

access	propertywith	permission	from	the	land	owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for	each	flight	to	be	conducted. 28) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries ofthe operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS

-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per	instructions	contained	on	the	NTSB	Web	site:www.ntsb.gov

.


### Specific Uses Public Benefits

Current procedures can result in significant injuries to the people who must climb on the roofs or require the use of aircraft that are orders of magnitude greater in size than	the	sUAV

. Either	method,	manual	inspection	or	large	conventional	aircraft, results in increased risk of injury due to personnel falling off roofs or ladders, carrying heavy ladders and dealing with confined and dangerous spaces, or increased risk from low altitude flyovers with helicopters or fixed wing aircraft inspecting buildings after damage from storms or other disasters, such as earthquakes or fires. Such flights are, of course, significantly more expensive than those	undertaken	with	a	sUAV

. The present system exposes those not only in the immediate area ofinspection, but those who are along the path of flight associated with the arrival and departure ofPage 14

the conventional aircraft atthe inspection site	because the aircraft mustbe flown to and from the site. By contrast, the sUAV is carried to the site and transits no other property. Conventional aircraft carry flammable fuels that are not carried by the UAS and emit pollutants associated with internal combustion engines. The sUAV’s proposed	herein	are battery	powered	and	have	no	emissions.


### Equivalent Level of Safety
**14	C.F.R.	§	61.113(a)	&	(b);:	Private	Pilot	Privileges	and Limitations;	Pilot	in**  **Command;**
Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the RoboFlicks’ sUAV is remotely controlled with no passengers or property of others on board. Section	61.133(a)	requires	an	individual	with	a commercial	pilot’s	license	to	be	pilot in	command	of	an	aircraft	for	compensation	or	hire

. RoboFlicks respectfully proposes that Operator requirements should take into account the characteristics of the particular UAS. RoboFlicks’ sUAV has a high degree of pre-programmed control and various built

-in technical capabilities that strictly limitthe	potential	for	operation outside	of	the	operating	conditions	set	forth in the exemption application. RoboFlicks’ sUAV has navigation and control system comprised ofa Ground Control Station (GCS) and auto
-pilot system that can be preprogrammed to set operational boundaries

. All flights are pre-programmed with precision GPS guidance

. In the case of unplanned events, the Operator may input pre-programmed evasive maneuvers from the control unit, and the onboard autopilot executes those maneuvers. Pre

-programmed Operator interventions include initiation of holding at present position; suspension of mission; fly back to launch	point;	abort	mission	and	land	immediately;	and emergency	power	cut	off	and land	(Flight	Termination	System).
Additional automated safety functions and safety enhancing features of the Sky Aerial	Drones’ sUAV’s mayinclude	the following: 1.1. Auto

-pilot detection of lost GPS or of insuf ficient satellites initiates an immediate landing. 1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 10%levels.	Low	power	beyond	10%	triggers	an	immediate	landing. 1.3. Ifthe auto
-pilot detects a lost

-linktothe ground controller,the UASwill hold position	at	its	current	location	for	5	seconds	and	if	the	signal	is	not restored, execute	a	return	to	home	and	land. 1.4. Redundant “kill switches” that enable completely shutting the aircraft down in flight in the event of a loss of control or un-commanded deviation	from	the	flight	path. 1.5.	The	aircraft,	weighs	less	than 55lbs.,fully	loaded.Page 15 1.6. The motors are driven by pulse width modulated signals, not analog signals. 1.7. The aircraft will operate for the Purposes at no more than 15 mph (while imaging) nor above 200 feet above the structure (imaging altitude)	or	a	maximum	of400 AGL.



### 14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation ofthe UAS without an airworthiness certificate, no standard will exist for airworthiness ofthe UA. Given the size ofthe aircraft and the requirements thatthe Operator has agreedto as it relatesto airworthiness, as contained inthe manual, an equivalent level ofsafety will be achieved by insuring compliance with the manuals prior to each flight. The FAA has granted exemptions to conduct similar operations in	Exemptions	11062	through	11067,	11080	and	11110.



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

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 200 AGL,	an	exemption	may	be	needed	to	allow	such	operations.	.
The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission ofthe property owner, facility owner, and/or local officials. Because of	the	advance	notice	to	the property	owner	and	participants,	all	affected	individuals willbe	aware	of	the	planned	flight operations	as	set	forth	in	the	Manuals.	Compared to flight operationswith aircraft or rotorcraftweighing far morethan the maximum 55 lbs. and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented by conventional aircraft operating at or below 500 AGL in the aerial photography industry. In addition, the low

-altitude operations ofthe sUAS will ensure separation between these small

-UAS operations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemptions 11062	through	11067,	11080	and 11110.Page 16



### 14 C.F.R. §91.121 Altimeter Settings

The RoboFlicks’ sUAV, in manual or emergency mode, will not have a barometric altimeter display, but instead a GPS altitude display, an exemption will be needed. The Operator, pursuant to the procedures set forth in the Manuals as indicated before flight, will achieve an equivalent level of safety

. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and	11110.


### 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or	(2)	At	night,	to	fly	after	that	for	at	least	45 minutes.”
The battery powering the sUAS provides approximately 40 minutes of powered flight. To meet the 30

-minute reserve requirement in 14 CFR §91.151, sUAS flights would	be	limited	to approximately	10	minutes	in	length.	Given	the	limitations	on	the UAS’ proposed flight area and the location of its proposed operations within a predetermined	area,	a	longer	time	frame	for flight	is	reasonable.
Petitioner believesthat	an exemption	from	14 CFR	§91.151(a)	falls	within	the	scope ofprior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives	who	have	signedwaiverswill be	allowed,	with	less	than	30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended	to	alleviate	given	the	size	and	speed	of	the	small	UAS.
Petitioner believes that an equivalent level of saf ety can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone f rom anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions	11062,	through11067,	11080	and	11110.


### 14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); **91.417(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	requiredPage 17

inspections, except as provided in paragraph (c) ofthis 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 the Petitioner

. Maintenance will be accomplished by the Operator or manufacturer pursuant to the flight manual and operating handbook as referenced in the Manuals attached as confidential Exhibits An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in defined areas for limited	periods	of	time.	If	mechanical	issues	arise,	the	UAS can	land	immediately	and will be operating f

rom no higher than 400 feet AGL. As provided in the Aircraft Flight Operations Manual the Operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the Operator and manufacturer are most familiar with the aircraft and best suited to maintain the aircraft in an airworthy conditionto providethe equivalent level ofsafety. The FAA has granted exemptions for	similar	operations	in	Exemptions	11062	through 11067,	11080	and	11110.



## Fede**ra l R** **egister Publication**

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal	Register,	should	it	be	determined	that	publication	is	needed:
Petitioner seeks	an	exemption	from	the following	rules: 14	C.F.R.	§§	61.113(a)	&	(b);	91.7(a);	91.119;	91.121;	91.151(a);	91.405(a); 91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge inspections, flare stack inspection, utility

-power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed and live	newsgathering,	training	to	persons	individually	or	belonging	to	both	private	and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools. colleges, professional sports, open air events and fairs, research, risk managementPage 18

and assessment, motion picture production, surface mining, closed set filming, disaster	and	catastrophe	events.



## Priv**acy and Nation al Security** 
All	flights	will	occur	over	private	or	controlled	access	property	with	the	property owner’sprior	consent	and	knowledge.	Inspection	will	be	of	inanimate	objects	in areas	where	the	owners will	have	consented	to	the	inspections	or	otherwise	have agreed	to	allow	the	UAS	and	the Operator	to	be	in	the	area	where operations will take	place. The	size	of	the	UAS,	its	speed	and	restricted	area	of	operation	do	not	raise	national security	issues.


## Summary
Approval of exemptions allowing commercial operations ofsUAV’s for petitioner to operate an unmanned aircraft system (UAS) to conduct bridge Inspections, flare stack inspection, utility

-power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority	officials,	aerial	video	and	photography	for	public	and	private	use	including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools. colleges, professional sports, open air events and fairs, research, risk management and assessment, motion picture production, surface mining, closed set filming, disaster and	catastrophe	events,will	enhance safety	by	reducing	risk.
Conventional operations, using jet or piston powered aircraft, ladders or placing people in	swamps, on	roofs	or	tall,	hazardous	or	weakened structures,	exposes	them to higher risks than those created by use of a sUAV’S

. Conventional aircraft that operate at extremely low altitudes just feet from the subject being inspected and in extreme proximity to people and structures present the risks associated with vehicles that weigh in excess of 6,000 lbs., carrying large amounts ofjet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the project location. In contrast, a sUAV weighing fewer than 14 lbs. and powered by batteriesPage 19

eliminates virtually all ofthat risk given the reduced mass and lack of combustible fuel carried on board. The sUAV is carried to the target area and not flown. The sUAV will carry no passengers or crew and, therefore, will not expose them to the risks	associated	with	manned aircraft	flights.
The operation of small UASs, weighing less than 55 lbs., conducted under the strict conditions outlined above, will provide an equivalent level of safety supporting the grant	of	the exemptions	requested	herein.	These	lightweight	aircraft	operate	at	slow speeds, close to the ground, and in areas that are under the control ofthe customer for the operations and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people	or	the	use	of	individuals	to	climb	the	structures	to conduct	the operations

. Satisfaction ofthe criteria provided in Section 333 ofthe Reform Act of 2012

–size, weight, speed, operating capabilities, proximityto airports and populated areas and operation within visual line of sight and national security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of Petitioner’s UAS for the Purposes outlined herein and are consistent with exemptions already granted, including Exemptions number 11171 through	11174,	and	11176.

Sincerely, Brad	Bollig RoboFlicks,	LLC 413	S.	Portland	St Bancroft,	IA	50517Page 20