May

7, 2015
U.S. Department of Transportation Docket Management System 1200 New Jersey

Ave., SE Washington, DC 20590
Re: Exemption Request Under Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

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, Unlimited Aerial Systems (“Unlimited Aerial S ys tems”), the developer and operator of the Scout and Boomerang small Unmanned Aircraft S ys tems ( “sUAS”) , seeks an exemption from the Federal Aviation Regulations (“FARs”) listed below and discussed in Appendix A. Details of Unlimited Aerial Systems and the Boomerang sUAS are described in Appendix B. Attached as Appendix C is a summary of this request

. The requested exemption would permit Unlimited Aerial Sy stems commercial operation of Unlimited Aerial System’s Boomerang (see details in Appendix B), which weighs 6 lbs. with imaging payload, to perform market research, aerial surveys, mapping, and ins pections that consist of still photographs, video, and other data taken by onboard sensors. The Boomerang produces high quality imagery and data that can be used independently - or in the case of surveying and modeling, can be combined to produce precision digital point clouds, triangle models, and contour maps of the survey ed area. Applic ations for these sUAS’s include: surveillance for Law Enforcement and Public Safety, intelligence and real

- time imagery to aid in firefighting and investigative actions, i nspection of sensitive infrastructure including oil and gases pipelines and flare stacks, power lines and towers, wind turbines, and survey ing tasks such as precision agriculture, mining, transportation, and forestry. Use of the Boomerang for these inspect ion and surveying applications reduces the need to operate conventional aircraft, providing data more quickly, accuratel y, economically, safel y, and with reduced environmental impact. Operations under the exemption will be subject to strict operating requ irements and conditions to ensure at least an equivalent level of safet y to currently authorized operations using manned aircraft and under conditions as may be modified by

the FAA as required by

Section 333. While Unlimited Aerial Systems is filing this exemption request on its own behalf, it anticipates that its customers, in the future, will file exemption applications to allow them to operate the Boomerang in commercial operations at their own facilities, farms, mines, and other sites thatrequire aeri al data for inspections and survey s. Wherever possible, those filings will be

substantially

similar to this exemption application. As described more full y below, the requested exemption would authorize Unlimited Aerial Sy stems to perform market research and commercial operations of aerial inspections and survey s using the Boomerang, which at 6 lbs. is small in size and powered electrically by battery . The Boomerang will be operated under controlled conditions at low altitude in airspace that is limited in scope, as described more full y herein ; It will have automated control features, as described below. The Unlimited Aerial Sy stems Boomerang is designed to be operated by one person but flight operations generally involve two people: an operator and an obser ver. The operator is responsible for fl yi ng the sUAS, monitoring its status and flight dy namics while maintaining visual line of sight, and keeping the flight within the specified factory limits (in terms of wind, flight range, battery

life, etc. ) to ensur e safe operation of the sUAS itself. The observer is responsible for monitoring the airspace for other aircraft and hazards and instructing the operator before and during flight as necessary to ensure safe separation/de-confliction with these aircraft and hazards. The operator also will be an individual who has passed an FAA approved or equivalent ground training exam and authorized Unlimited Aerial Sy stems training program for the Boomerang. Finally , the airspace in which the Boomerang will operate will be disclosed to and approved, as needed, by the FAA in advance. Unlimited Aerial Sy stems respectfull y submits that because this small, unmanned aerial s ys tem

– the Boomerang

– will be used in lieu of comparatively hazardous operations now conducted with fix ed wing and rotary

conventional aircraft, the FAA can have confidence that the operations will achieve at least an equivalent level or greater level of safety. Approval of this exemption would thereb y enhance safet y and fulfill the Secretary of Transportat ion’s (the FAA Administrator’s) responsibilities under Section 333(c) of the Reform Act to “establish requirements for the safe operation of such aircraft sy stems in the national airspace s ys tem.” The name and address of the applicant are: Unlimited Aerial Sy stems Attn: Chad Swan Ph: 850

- 332

- 7022 Fax: 850

- 477

- 2127 Email: Chad@CreativeDevSol.com Address: 5945 Creek Side Circle, Pensacola, FL 32504 The primary

contact for this application is: Unlimited Aerial Sy stems David Sweeney , Sweeney us mc@gmail.com, 318

- 332

- 7192 The regulations from which the exemption is requested are as follows: 14 C.F.R. Part 21 ; 14 C.F.R. 45.23(b) ; 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. 91.9(b)(2) & (c) ;

14 C.F.R. 91.103 ; 14 C.F .R. 91.109(a) ; 14 C.F.R. 91.119 ; 14 C.F.R. 91.151(a) ; 14 C.F.R. 91.203(a) & (b) ; 14 C.F.R. 91.405(a) ; 14 C.F.R. 91.407(a)(1) ; 14 C.F.R. 91.409(a)(2) ; 14 C.F.R. 91.417(a)
Appendix A discusses each rule listed above and explains why exemptions pursuant to the proposal set forth in this letter are appropriate, provide an equivalent level of safety, and are in the public interest.
THE APPLICABLE LEGAL STANDARD UNDER SECTI ON 333 Unlimited Aerial Sy stems submits that grant of this exemption application for use of the Boomerang in market research, surveying, mapping and inspection operations will advance the Congressional mandate in Section 333 of the Reform Act to accelerate t he introduction of sUASs into the national airspace sy stem (“NAS”) if it can be accomplished safel y. This law directs the Secretary of Transportation to consider whether certain sUASs may operate safel y in the NAS before completion of the rulemaking requir ed under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which ty pes of sUASs 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: ● T he sUAS’s size, weight, speed, and operational capability ; ● Operation of the sUAS in close proximity to airports and populated areas ; and ● Operation of the sUAS within visual line of sight of the operator.
Reform Act § 333(a)(1). If the Secretary deter mines that such vehicles “may operate safel y in the national airspace s ys tem, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace s ys tem.” Id. §333(c) (emphasis added). The Federal Aviation Act expre ssly grants the FAA the authority to issue exemptions. This statutory authorit y, b y its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator may

grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or an y of sections 44702-44716 of this title if the Administrator finds the exemption is in the public interest.49 U.S.C. §44701(f). See also 49 USC §44711(a) ; 49 USC §44704; 14 CFR §91.203(a)(1).

The grant of the requested exemption is in the public interest based on th e clear direction in Section 333 of the Reform Act ; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level of safet y surrounding the proposed operations ; and the significant public benefit, including enhanced safety and cost savings associated with transitioning to sUASs for aerial surveying, mapping and inspection applications. Accordingl y, the applicant respectfull y requests that the FAA grant the requested exemption without delay

. Airworthiness of the Boomerang
A critical element of the exemption application involves evidence of the airworthiness of Unlimited Aerial Sy stems sUAS including the Boomerang. Unlimited Aerial Sy stems believes that it has shown compliance through successful flights - including man y operat ions with public agencies. There have been numerous successful flights with University of Louisiana, Monroe, University

of California, Davis, numerous state government entities of Louisiana and commercial service providers such as VDOS LL C.
Applicant sub mits that this provision places a dut y on the Administrator to not only process applications for exemptions under Section 333, but for the Administrator, if he deems the conditions proposed herein require modification in order to allow approval, to supply conditions for the safe operation of the sUAS. Unlimited Aerial Sy stems welcomes the opportunity to consult with FAA staff in order to address an y issues or concerns that this proposal may raise that they believe may

require modification. The Boomerang als o has a significant set of automated features to ensure safe takeoff, flight and landing in man y conditions, further details of operation can be found in Appendix B. Mandatory

Operating Conditions Grant of the exemption to Unlimited Aerial Sy stems will be subject to the following mandatory conditions, which are based upon operating conditions set forth for operation of sUAS by public entities pursuant to Certificates of Authorization, with additional restrictions: ● All operations to occur in Class G ai rspace ● Operations to avoid congested or populated areas, which are d epicted in yellow on VFR charts ● Operations to be conducted over private or controlled access propert y ● Permission from land owner/controller required before commencing any flight ● Op erations to occur during Visual Flight Rules Meteorological Conditions ( “ VMC ” ) ● Aircraft to remain within Visual L ine of Sight ( “ VLOS ” ) ● VLOS guaranteed with a cylinder of operation around operator of 1⁄2 nautical miles ( “NM ” ) ● Cylinder walls may

be expan ded b y observer with ability to control aircraft ● Operations to occur during daylight hours● Above Ground Level ( “ AGL ” ) altitude to be restricted to 400 feet

● All operations conducted in vicinity of airport to remain more than 2.5 NM from centerline azimuth of runway

centerline measured from runway thresholds ● Operator will file a NOTAM for each flight ● All required permissions and permits will be obtained from territorial, state, count y or cit y jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. ● All operations will include one pilot for flight control and one observer for VLOS enhancement of surrounding area near the aircraft Operator Requirements: Unlimited Aerial Sy stems respectfull y proposes that operator requirements should take into account the characteristics of the particular sUAS. Certain sUASs, such as the Unlimited Aerial Sy stems Boomerang, are characterized b y a high degree of pre-programmed control and various built

- in technical capabiliti es that limit the potential for operation outside of the operating conditions set forth above. The Boomerang sUAS also provides man y built

- in functional and safet y features to assist the operator in safe and reliable operation. Unlimited Aerial S ys tems can submit under confidentiality the following documents in support of this exemption application for the Boomerang: 1) Unlimited Aerial Sy stems Boomerang User Guide (Exhibit 1) which includes Safet y and Pre

- Flight Checklists ; and 2) Training Manual (Exhibit 2). As of May

2015, Unlimited Aerial S ys tems staff and customers have performed over 200 flights, logging 120 hours of flight time with the Boomerang with both development and release versions. The previous generation product, Scout, achieved over 7 , 197 fl ights and 839 hours of flight time globall y b y Unlimited Aerial Systems and its customers. This is a significant amount of flight time collected to understand and refine the Unlimited Aerial Sy stems sUAS products. The Unlimited Aerial S ystems Boomerang pr ovides two semi-autonomous flight modes using a point-and-click map and video interface. The user clicks on a map to direct the Boomerang to fl y to the point on the map where the operator is pointing, or programmed flight plans may be entered for a series of way points or grid-based area. Additional navigation aids including landing zones and flight areas may be designated to ensure the Boomerang operates only within user specified flight parameters. All flight operations are GPS controlled making the s ys tem easy to navigate, and the flight control sy stem also employ s a variet y of sensors including sonar, barometric pressure, temperature, wind speed and others to ensure the high stability and reliability in challenging weather conditions. At all times during fl ight operations, the operator can intervene a programmed flight and take immediate control. Additional automated safety functions and safet y enhancing features of the Boomerang include the following: ● Automated pre-flight sy stem performance checks ● User pre-flight checklist ● Automated condition or fault detection, warnings, and pre-defined responses to a number of flight and s ys tem conditions.

◦ High winds with sy stem and user defined safety thresholds

◦ Lo w battery

with sy stem and user defined safety thresholds

◦ High temperature or other s ys tem safety thresholds◦ Lo st-link communication

● Pre-defined responses include behavior such as attempting to re-establish radio communication, return to home position and hover, return to home position and land, or land in current position ● Inthe case of lost GPS, a manual user flight mode is enabled which allows the operator to provide manual navigation inputs to assist in landing the vehicle. Given these safet y features, Unlimited Aerial Systems proposes that operators of the Boomerang should not be required to hold a commercial or private pilot certification. Instead, operators should be required to: ● have successfull y completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA-recognized equivalents including commercial or private license and ground school issued from an I CAO recognized country ; ● have completed Unlimited Aerial Sy stem’ s authorized training program for operation and maintenance o f the sUAS. Unlimited Aerial Sy stems notes that the FAA has found that safet y factors permitted operation of sUASs by operators with these qualifications in the case of operations pursuant to public COAs when the mandatory

operating conditions specified a bove were present. See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Sy stems (UAS) Operational Approval, at 20-21 (July

30, 2013). The FAA has the statutory authorit y to grant exemptions to the requirements for and privileges associ ated with the grant of airmen’s certificates. 49 USC §44701 (f). In summary , applicant seeks an exemption from the FARs set forth above and in Appendix C to allow market research and commercial operations of a small unmanned vehicle in surveying, mapping and inspection operations. Approval of the exemption allowing commercial operations of the Boomerang for surveying, mapping and inspection operations will enhance safety b y reducing risk. Conventional aerial survey and inspection operations using manned aircraft involve very heavy aerial vehicles carryi ng significant quantities of combustible fuels, and a militiaperson crew in piloting and observation roles. These operations require transit to and from the location of the activity , and often take place in congested environments including proximity to phy sical obstacles and/or presence of the general public. By contrast, the Boomerang weighs 6 lbs. including payloads and uses a battery

for power, is carried to/from the area of activit y, removes the need for airborne pilots/observers, and poses less risk to people and infrastructure on the ground. Additionally , no national securit y issue is raised by the grant of the requested exemptions. Given the size, load carrying capacity , speed at which it operates, and the fact that it carries no explosives or other dangerous materials, the Boomerang poses no threat to national securit y. The operation of the Boomerang for market research, surveying, mapping and inspection operations in accordance with the strict condit ions outlined above, will provide an equivalentlevel of safety supporting the grant of the exemptions requested herein, including exempting Unlimited Aerial Sy stems from the requirements of Part 21. The Boomerang’s satisfaction of the criteria set forth in Section 333 of the Reform Act

— size, weight, speed, operating capabilities, lack of proximity to airports and populated areas, operation within visual line of sight, and national security

– and its showing of an equivalent level of safety as it may relat e to the requirement for a pilot’s license, provide more than adequate justification for the grant of the requested exemptions allowing Unlimited Aerial Sy stems commercial operation of the Boomerang in market research, surveying, mapping and inspection ope rations. Very trul y yours, Chad D. Swan Unlimited Aerial Sy stemsAPPENDIX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWI NGS UNDER APPLICABLE RULES SUBJECT TO EXEMPTION Unlimited Aerial Sy stems requests an exemption from the following regulations as well as an y additional regulations that may technicall y appl y t o the operation of the Boomerang: 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203(a)(1)
Section 91.203(a)(1) requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a)(1). Given the size of the aircraft (6 lbs.) and the limited operating area associated with its utilization, it is unnecessary to go through the certificate of airworthiness process under Part 21 Subpart H to achieve or exceed current safet y levels. Such an exemption meets the requirements of an equ ivalent level of safet y under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the s ize, weight, speed, operational capability , and proximity to airports and populated areas of the sUAS involved. In this case, an anal ys is of these criteria demonstrates that the Boomerang operated without an airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The Boomerang weighs 6 lbs. fully loaded. It will not carry

a pilot or passenger, will not carry flammable fuel , and will operate exclusively within an area pre-disclosed and in compliance with conditions set forth herein. Operations under this exemption will be tightly controlled and monitored by

both the operator, pursuant to the conditions set forth above, and b y local public safet y requirements. The FAA will have advance notice of all operations through the filing of NOTAMs. Receipt of the prior permission of the land owner, the size of the aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not flown there all establish the equivalent level of safet y. The Boomerang provides at least an equivalent, and most likely exceeds, a level of safet y to that of such operations being conducted with conventional aircraft that w ould be exponentially larger and would be carrying passengers, cargo, and flammable fuel. The automated safety features including redundant sensor sy stems as described in Appendix B and throughout this document highlight the design intentions towards safety and reliability on Boomerang. An Unlimited Aerial Sy stems internal report compares the crash kinetic energy dissipation rate of a commercial airline versus the Unlimited Aerial Sy stems Boomerang. The report found the MTTF of Boomerang needs to only be > 2.3 hours to equal the energy dissipation of the goldstandard commercial aircraft. Transport Canada has issued a report on low energy RPA and determined the Unlimited Aerial S ys tems Scout, at a ty pical max kinetic energy

of 1.45 J/cm 2 , to be well below the recommended peak energy level of 12 J/cm2 on impact

. S ince the Boomerang is similar in construction , it could be considered to be below this threshold as well. 14 C.F.R. § 45.23 & 91.9(c): Marking of the Aircraft Regulation 45.23 provides: (a) Each operator of an aircraft must display on that aircraft marks consisting of the Roman capital letter “N” (denoting United States registration) followed b y the registration number of the aircraft. Each suffix letter used in the marks displayed must also be a Roman capital letter. (b) When marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light sport category aircraft or experimental or provisionally certificated aircraft, the operator must also d isplay on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light sport,” “experimental,” or “provisional,” as applicable. Regulatio n 91.9(c) provides: No person may

operate a US registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter. The Boomerang has no entrance to the cabin, cockpit, or pilot station on which the markings can be placed. Given the size of the sUAS, two

- inch lettering will be impossible. Of ficial marking sy stems for small UAS have not y et been established for operations inside the NAS. The Boomerang is currently

marked with a fixed label containing “ Unlimited Aerial Sy stems Labs Boomerang ” measuring 1.5” x 0.5” as well as a serial number located under the removable camera payload. Unlimited Aerial S ys tems is prepared to mark the inspection sy stem with the name of the organization and location or origin and ful fill an y other request by the FAA to this topic in accordance to § 45.29(f) where the pilot, observer, and others working with the sUAS will see the identification of the sUAS. The FAA has issued the following exemptions to this regulation; see Exemption Nos. 8738, 10167, 10167A and 10700. 14 C.F.R. § 61.113(a) & (b) ; 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command ; Commercial Pilot Privileges and Limitations.
Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the Boomerang in this case is remotely controlled with no passengers or propert y of oth ers 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. Unlimited Aerial Sy stems respectfully proposes that operator requirements should take into account the characteristics of the particular sUAS. Unlimited Aerial S ys tems’s Boomerang has a high degree of pre-programmed control and various built

- in technical capabilities that strictly

limit the potential for operation outside of the operating conditions set forth in the exemption application.The Boomerang has an all-digital software platform with advanced features previously restricted to full size unmanned aircraft. Automated features and advanced fl y-s afe controls enable safe, reliable operation, as well as advanced networking capabilities and s ys tem extensibility

. ● Plan your flight or fl y manually : The s ys tem can autonomously fl y a programmed flight path or fly in manual mode ● Smart batteries and charger: Flight time and battery minutes are displayed at all times. The sy stem will return home and land automaticall y if user configurable limits are reached. Flight safet y is a priorit y, no matter the operating environment or project. The Boomerang offers superior safet y over manned aircraft b y removing the ne ed for people to be onboard in potentially

dangerous situations. With multiple built

- in safety features, the Unlimited Aerial Sy stems platform leads other sUAS with respect to safety. ● Intelligent fault handling: The s ys tem automatically detects potential issues - with configurable automated response behavior such as a return-home-and-land routine ● Automatic pre-flight checks: The s ys tem self

- calibrates all of its sensors and performs self-tests prior to takeoff to check for errors ● No-fl y zones: The s ys tem has the ability to set up visual no-fly

zones ● Self-monitoring: Monitoring battery levels, in-flight wind speeds, and other s ys tem and environmental conditions are automatically handled by

the s ys tem ● Battery

communication: Battery

minutes and flight time are displayed at all times. The sy stem will return home and land automatically if user-configurable limits are reached. Additional automated safety functions and safet y enhancing features of the Boomerang include the following: ● Auto detection of l ost GPS warns the pilot and initiates an immediate landing. ● Lo w battery

on the Boomerang triggers a Non

- Fatal Warning alarm to return home, land and replace the battery ● Very low battery

on the Boomerang triggers a Fatal Error alarm and initiates an eme rgency high speed descent landing. ● If the Boomerang detects a lost

- link to the base station the vehicle will perform its pre-defined Non-Fatal, Condition Response.

Given these safet y features, Unlimited Aerial Systems proposes that operators of the Boomerang should not be required to hold a commercial or private pilot certification. Instead, operators should be required to: ● have successfull y completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written exami nation or FAA-recognized equivalents including ICAO issued commercial, private license and ground school ; ● have completed Unlimited Aerial Sy stems ’ s training program for operation of the sUAS. Unlimited Aerial Sy stems notes that the FAA has found that sa fet y factors permitted operation of sUASs by operators with these qualifications in the case of operations pursuant to public COAs where the mandatory

operating conditions specified above are present. See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Sy stems (UAS) Operational Approval,at 20-21 (July 30, 2013). The FAA has the statutory authorit y, granted at 49 U.S.C.§44701(f) to waive the pilot requirements for commercial operations. Given these conditions and restrictions, an equi valent level of safety will be provided by allowing operation of the Boomerang without a private pilot’s certificate or a commercial pilot’s certificate, under the conditions set forth herein. The risks associated with the operation of the Boomerang (give n 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 Part 61 with conventional aircraft (fixed wing or rotorcra ft), that allowing operations of the sUAS as set forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the aircraft under § 61.133(a). 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 of the Boomerang without an airworthiness certificate, no standard will exist for airworthiness of the Boomerang. Given the size of the aircraft and the previous COAs issued for Unlimited Aerial Systems’s Scout and Boomerang, an equivalent level of safety will be achieved b y ensuring compli ance with the Unlimited Aerial Sy stems manuals prior to each flight. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft.
The regulation provides: No person may

operate a US registered civil aircraft ...
(2) For which an Airplane or Rot orcraft Flight Manual is not required b y §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. Given the size and configuration of the Boomerang, it has no ability or place to carry

such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacit y to carry such an item on the aircraft. The equivalent leve l of safet y will be achieved b y keeping the flight manual (see, e.g., User Guide, Exhibit 1) at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued to others the following exemptions to this regulat ion: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take certain actions before flight to insure the safet y of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft , an exemption will be needed. An equivalent level of safet y will be provided as set forth in the Boomerang User Manual (exhibit 1) under the ‘Getting Ready to Fl y’ sect ion. The PI C will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.
14 C.F.R. § 91.109(a) & 91.319(a)(1): Flight Instruction These regulati ons provide that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has full y functioning dual controls. The Boomerang is a remotely piloted aircraft and by

design, does not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio communications. The flight plan is either manuall y controlled through point-and-click touchscreen navigation or pre-programmed as way points or an Auto Grid into the auto pilot before or during flight and onl y in unusual circumstances will the pilot input control functions to alter the pre-programmed flight. If instruction is accomplished through a training progr am, as set forth in Exhibit 2, an equivalent level of safety will be assured. The FAA has approved exemptions for flight training without fully functional, dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exem ption Nos. 5778K & 9862A. The equivalent level of safet y will be achieved b y the manufacturer providing the training as outlined, for example, in Exhibit 2 and through the use of experienced and qualified pilots familiar with the Boomerang.
14 CFR § 91.1 19: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically , 91.119(c) limits aircraft fl yi ng over areas other than congested areas to an altitude of 500 feet above the surface, except over open water or sparsel y populated areas. In those cases, the aircraft may not be operated closer than 500 feet to an y person, vessel, vehicle, or structure. As set forth herein, the Boomerang will never operate at higher than 500 feet AGL. It will, however, be operated to avoid congested or populated areas that are depicted in y ellow on VFR sectional charts. Because aerial survey , mapping and inspection work must be accomplished at relativel y low altitudes and at altitudes less than 500 feet AGL, an exemption from Se ction 91.119(c) is needed. The equivalent level of safet y will be achieved given the size, weight, speed, and material with which the Boomerang is built. Also, no flight will be taken without the permission of the landowner or those who control the land. Because of the advance notice to the landowner, allaffected individuals will be aware of the flights. Compared to aerial survey operations conducted with aircraft or rotorcraft weighing far more than 6 lbs. and carrying flammable fuel, any risk associated with these operations will be far less than those currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the low altitude operations of the sUAS will maintain separation between these sUAS operations and the operations of conventional aircraft that must comply

with Section 91.119.
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions This regulation prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering w ind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assumi ng normal cruising speed

– (1) d uring the day , to fly after that f

or at least 30 minutes ; or (2) at night, to fly after that for at least 45 minutes.” The Boomerang batteries provide approximately 50 minutes of powered flight. Without an exemption from § 14 CFR 91.151, the sUAS’s flights would be limited to approximately 20 minutes in length. Given the limitations on its proposed operations an d the location of those proposed operations, a longer time frame for flight in daylight VFR conditions is reasonable. Unlimited Aerial Sy stems believes that an exemption from 14 CFR § 91.151(a) is safe and within the scope of a prior exemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151(a)). Operating the sUAS, without 30 minutes of reserve fuel does not engender the t ype of risks that Section 91.151(a) was meant to prevent given the size and speed at which the sUAS operates. The fact that it carries no pilot, passenger, or cargo also enhances its safet y. Additionally , limiting Boomerang flights to 20 minutes would greatly

reduce their utility . In the unlikely event that the Boomerang should run out o f fuel, it would simply land. Given its weight and construction material, the risks are less than contemplated b y the current regulation. Unlimited Aerial Sy stems believes that an equivalent level of safet y can be achieved b y maintaining 10 minutes of reserve fuel, which, allowing 40 minutes of flight time, would be more than adequate to return the sUAS to its planned landing zone from an ywhere in its operating area.
The FAA has granted similar exemptions to others, including Exemptions 2689F, 5745, 1 0673 and 10808.
14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircraft Certification and Registration This regulation provides as follows: (a) ... no person may

operate a civil aircraft unless it has ... an appropriate and current airworthiness certificate.(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is display ed at the cabin or cockpit entrance so that it is legible to passenge rs or crew. The Boomerang full y loaded weighs approximately 6 lbs. As such, there is no ability or place to carry certification and registration documents or to display them on the sUAS. In addition, there is no pilot on board the aircraft. An equivalent level of safety will be achieved by

keeping these documents at the ground control point where the pilot fl yi ng the sUAS will have immediate access to them. The FAA has issued numerous exemptions to this regulation. A representative sample of other excepti ons includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.
14 C.F.R. § 91.405(a) ; 407(a)(1); 409(a)(2); 417(a): Maintenance Inspections Section 91.405(a) requires that an aircraft operator or owner “shall have that aircraft insp ected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter ...” Section 91.407 similarly makes reference to requirements in Part 43 ; Section 91.409(a)(2) requires an annual inspection for the issuance of an air

- worthiness certificate. Section 91.417(a) requires the owner or operator to keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records of approval of the aircraft for return to service. The Boomerang is nearl y maintenance free, it performs automatic pre- flight checks and the failure of an y check will prevent take-off. C hecks, which cannot be done by the sy stem, will be performed b y a quali fied person prior to each flight and at predefined intervals as part of the Maintenance Schedule in the User Manual (see Exhibit 1).
Pre- fli ght checklist includes: 1. Visual inspection of the airframe 2. Visual inspections of rotor integrit y 3. Check charge of all batteries (aerial vehicle, command station, radio repeater station) An equivalent level of safety will be achieved because the sUAS is small in size, will carry no external payload, will operate onl y in restricted predetermined areas and is not a complex mechanical devise. As provided in the attached User Guide (S ys tem Maintenance section), the operator of Boomerang will ensure that the sUAS is in working order prior to initi ating flight, perform required maintenance, and keep a log of any maintenance that is performed. Moreover, the operator is the person most familiar with the aircraft and is best suited to maintain the aircraft in an airworth y condition and to ensure an equ ivalent level of safet y. The Boomerang’s Maintenance guidelines ensure an equivalent level of safety to the maintenance requirements in Part 91. In addition, any component failure detectable by the sy stem will be reported to the control station and will c ause the UAV to perform a FatalCondition Response ( “ FCR ” ) or Non-Fatal Conditioned Response ( “NFCR ” ), depending on the

ty pe of failure.APPENDIX B

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION Unlimited Aerial Sy stems Corporate Overview: Unlimited Aeri al Sy stems is a US based compan y located in Natchitoches, LA . Unlimited Aerial Sy stems is focused on providing a micro unmanned aerial s ys tem that is globall y recognized as the market and technology leader in this sector, with customers ranging from state government agencies to commercial operators. Also, United Aerial S ys tems is engaging w orld leading universities in the unmanned space , such as University

of Louisiana, Monroe and University of California, Davis ; Police agencies such as the Lafayette and New Orleans Police Department agencies ; And global enterprises such as Tekever and Fortune 500 companies in the chemical, oil/gas and security markets. Unl imited Aerial Sy stem s ’ sy stems have accumulated over 5 , 000 hours in global flight operations. Thi s number does not include military

flight hours, which inevitably would increase the numbers further. Boomerang Overview: Unlimited Aerial Sy stems unmanned s ys tems have been used to investigate power grid issues in Natchitoches, LA and provide imagery for Public Safety operations. The Unlimited Aerial S ystems Boomerang can carry payloads up to 500 g. The Boomerang flies with a maximum wind threshold of 15 mph for sustained winds and wind gusts up to 20 mph. What is unique about the Unlimited Aerial Sy ste ms Boomerang is the s ys tem automatically compensates for wind versus rel yi ng on the operator’s sense of feel’ for what the impact of the wind is at the altitude , in which the s ys tem is flying. The end result is a sy stem capable of gathering high quality

ae rial intelligence , at much higher wind thresholds. A trait that is imperative for man y aerial inspection operations. The Boomerang has an operational range of up to 1.8 km ( 1 NM) with the standard offering and up to 3.7 km ( 2 NM). All flight operations are GPS controlled , making the sy stem extremely easy to navigate. At any point , if the operator is not explicitly commanding the s ys tem to move, the sy stem automatically holds its GPS position (i.e. GPS hold for reliable location hover). Camera positioning is also GPS controlled allowing for the most sophisticated camera targeting available. The flight control sy stem employ s not only

GPS positioning , but also a variet y of sensors including sonar, barometric pressure, temperature, wind speed and others to ens ure the most stability of any sy stem in its class, regardless of the wind. The Unlimited Aerial S ystems Boomerang can be operated in both semi and fully autonomous flight modes. Creating preplanned flight paths to fly in autonomous mode is as simple as cl icking on the map to create a preplanned flight path. In semi-autonomous mode, the operator clicks on the map and the Unlimited Aerial S ys tems Boomerang automaticall y flies to the point on the map , where the operator is po inting. Pre-mission way points, l an ding zone points and flight area dimensions can all be entered during preflight , ensuring the Boomerang operates onl y within specified parameters.The Unlimited Aerial S ystems Boomerang includes many advanced safet y features that makes it

the safest choi ce for both urban and non-urban environments. Built

- in intelligent fault handling allows the Boomerang to detect a s ys tem fault while in the air, and to automatically fl y back to its take-off location and successfull y land. Faults that can be detected incl ude: loss of communication, pre-set wind thresholds exceeded, a nd low battery

levels. In addition, the operator can create no fl y zones or maximum flight ranges and altitudes , so the sy stem cannot enter areas deemed unsafe or unnecessary to fly over. And b efore every

take-off , automated flight checks ensure that the sy stem is flight ready before it takes off. The Unlimited Aerial S ystems Boomerang can be operated entirel y b y a touch-screen, map

based interface. This means the operator onl y needs to command the sy stem where to go, and the sy stem does all the flying for the operator. Maps can be saved and flight plans c an be made or recalled with no i nternet connection being required. Boomerang Operating Manual - S ys tem user manual available upon request. Phy sical Characteristics
Measurements

– 48” diameter Weight (without payload)

– 2.84 kg ( 6 lbs. ) Fuel

– Lithium poly

mer batteries are self

- contained high duration sy stems with “SMART” intelligence on-board. This includes cycle charge times, locations, GPS antenna, chemical management, and real

- time data feeds to ensure maximum flight duration and sub-s ys tem safet y processes. Charging is done in the included Unlimited Aerial S ys tems Battery charger and can be charged via standard wall outlet, or via a ve hicle. Landing st yl e/t ype

– Autonomous vertical lift Propulsion Sy stem ● Engines

– The Boomerang is powered by 4 electric brushless DC motors. ● Batteries

– Li thium poly mer batteries are self

- contained high duration sy stems with SMART intelligence on-board. This includes cycle charge times, locations, GPS antenna, chemical management, and real

- time data feeds to ensure maximum flight duration and sub-s ys tem safet y processes. Charging is done in the included Unlimited Aerial S ys tems Battery charger and can be charged via standard wall outlet, or via a vehicle. Performance Characteristics ● Maximum Altitude

– 2000 ft. ● Maximum Endurance

– 35 minutes ● Maximum Range

– 3.21 km or Visual L ine of Sight ● Weather Minimums - 1,000 ft Ceiling, 3 Miles V isability ● Winds Maximum

– 15 mph sustained, 20 mph gusts● Minimum ceiling: 500 ft.

● Minimum visibility : 1 SM ● Icing conditions

– no icing conditions ● Precipitation

– no visible moisture
Maintenance

– The UAS is nearl y maintenance free, it performs automatic pre-flight checks and the failure of an y check will prevent take-off. A qualified person prior to each flight will perform checks, which cannot be done by the sy stem. Pre-flight checklist includes: ● Visual inspection of the airframe ● Visual inspections of rotor integrity ● Check charge of all batteries (aerial vehicle, command station, radio repeater station) Reliability

– The sy stem is designed for maximum reliability and to maintain performance over its life. The only

components experience routine we ar are rotors, batteries, motors, and legs. Battery and motor conditions are monitored by the sy stem with deviations reported to the operator. Contact with other objects during flight may cause other components, particularly rotors, and motor arms, to bec ome damaged. Damaged components are likel y to be detected during the full visual inspection of the airframe , performed before each flight. On-board sensors will detect structural damage affecting flight characteristics. The UAV s ys tem detects numerous con ditions, which may make fl yi ng unsafe, such as reduced GPS accuracy , magnetic anomalies, low battery charge, battery

cell imbalances, and temperature fluctuations. Automatic pre-flight checks prevent the UAV from taking off if such conditions are present and/or if the condition is detected during flight, the s ys tem will trigger a Fatal Conditioned Response. Fault Tolerance - The key feature of the UAV fault tolerance is its mechanical simplicity . It uses four fixed pitched rotors, each mounted on a separat e motor. No control surfaces or other actuators are required for the UAS to fly . An y component failure detectable by the sy stem will be reported to the control station and will cause the UAV to perform a Fatal Condition Response (FCR) or Non-Fatal Conditio ned Response (NFCR), depending on the t yp e of failure. Command and Control Systems The Boomerang Ground Control station allows the operator simultaneous control over aircraft and payloads. The touch screen control allows for quick navigation and data entry while the display screen provides all essential flight data to the operator. Telemetry data is transmitted to the command station at least once per second. Displayed on GCS: ● UAS Position ● Navigation Route● UAS Tail Number

● UAS Position ● UAS Altitu de ● UAS Heading ● North Seeking Arrow ● Range to Target ● Calculated target position ● Date/time ● Sensor heading and orientation relative to UAS On-board Flight Instruments

– The UAV is equipped with an Inertial Navigation S ys tem (3-axis gy roscope, 3-axis magnetometer, GPS receiver, and static pressure sensor) and a sonar sensor for precision AGL altitude measurement. On

– board computer s ys tems

– The UAS is equipped with an on-board computer sy stems to monitor (sensors, battery , etc.), control (speeds, altitude, position, etc.), and communicate (control, telemetry , etc.). On-board guidance and navigation equipment

– The UAS can operate autonomousl y and does not require an y input from ground based equipment, or from the pilot to hover in place. Frequency

Allocations

– 9 15 MHz, 2.4 GHz, 5.8 GHz, 1.2 GHz , custom Flight termination link

– to prevent a “fl y awa y” or an y other potentiall y dangerous situation , a flight termination link is available to the operator at the GCS. Takeoff and Landing

– The Boomerang has vertical lift autonomous launch and recovery . A Landing Zone “LZ” , is designated b y the operators and identified in the GCS software. For la unch procedures , the aircraft will takeoff and hover 3 meters directl y above the LZ and hold until further operator instruction is given. The aircraft will automaticall y adjust for wind during this period. Navigation Sy stem

– Specific maps can be download ed to the display screen (such as air sectional and geographic maps), which are overlaid with GPS positional data. Way points can be created before and during flight operation , creating specific locations and sequences for the aircraft. Redundant Sy stems

– The UAS combines the input from a multitude of sensors. Even tho ugh the data from all sensors are required for optimal sy stem performance, a single sensor malfunction is likely to result in degraded performance rather than leading to a catastrophic failur e. Emergency

Procedures and Sy stem Failures Failure Handling

– The UAS has extensive failure detection and handling capabilities. All failures are deeded to be either fatal or non-fatal. Failures classified as fatal result in a Fatal Condition Response (F CR) , while failures classified as non-fatal result in a Non-Fatal Condition Response (NFCR).Sensor Failure

– Failure of on-board flight instruments/sensors will degrade the UAS

performance and will result in either a FCR or NFCR, depending on their severity . If the UAS becomes unstable due to sensor failure, it will stop all four motors and free fall to avoid a fl y away condition. Motor Failure

– The UAS flight performance will degrade significantly if one or more motors fail. Airframe Failure

– If airf rame is damaged in way s that impacts flight characteristics, the UAS will behave similar as if an on-board flight instrument failed. Navigation Sy stem Failure

– In a navigation sy stem failure, degraded GPS will result in FCR or NFCR‘s depending on failure s. Power Failure

– A complete battery failure that results in power loss to the UAS , will result in degraded flight performance. Low Battery

Condition

– The Operator will be alerted of a low battery condition and will land the aircraft as soon as able. Low Battery

Condition

– The Operator will be alerted of a low battery condition and will land the aircraft as soon as able. Line-of-Sight L oss

– All flight operations with the UAS will be conducted within visual sight of the pilot. I f the pilot’s view bec omes obstructed and line-of-sight is lost, the pilot may instruct the UAS to hover in place until line-of-sight is reestablished, to return to the take-off position, or to land at the current position. Security The manufacturer’s proprietary software encrypts the sy stem and communication links.APPENDIX C

SUMMARY OF UNLIMITED AERIAL SYSTEMS SECTION 333 EXEMPTI ON REQUEST Unlimited Aerial Sy stems hereby provides pursuant to Part 11 , a summary of its exemption application to allow commercial operation o f the Boomerang small unmanned sy stem in market research, precision aerial survey work, mapping and inspections. An exemption is requested from the following regulations:
14 C.F.R. Part 21 ; 14 C.F.R. 45.23(b) ; 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. 91.9(b)(2) & (c) ; 14 C.F.R. 91.103 ; 14 C.F.R. 91.109(a) ; 14 C.F.R. 91.119 ; 14 C.F.R. 91.151(a) ; 14 C.F.R. 91.203(a) & (b) ; 14 C.F.R. 91.405(a) ; 14 C.F.R. 91.407(a)(1) ; 14 C.F.R. 91.409(a)(2) ; 14 C.F.R. 91.417(a)