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Ms. Cher- yl Colliris 

Program Manager, Docket Operations 

Docket Managernent Facility 

U.S. Department of Transportation 

1200 New Jer- sey Avenue, SE 

West Building Ground Floor, Room W12-140 

Attn: FAA Dockets 

Wasfiington, DC 20590 

February 5, 2015 

Re: Amazon Logistics, lnc. — Petition for Exernption 

Dear- Ms. Collins: 

At Amazon, our- energy comes from inventing on behalf of custor7iers. Amazon Prirne 

Air, a new delivery system that will get packages to customer- s in 30 minutes or less using small 

aerial vehicles, is one inverition we are incredibly passioriate about. We believe customers will 

love it, and we are cornriiitted to r-naking Prime Air available to customers worldwide as soon as 

we are permitted to do so. 

Prime Air is an irinovation we have been wor - king on for some tirrre. We ar- e rapidly 

experimenting and iter- ating on our Prirne Air vehicles inside our next generation research arrd 

development lab in Seattle. Aniazon is also in the process of seeking the first in a series of 

experirnental cer-tificates fr- oni FAA to continue our development efforts for- Prime Air outdoors 

in the United States, witli the goal of flying safely and soon. 

Following the recent FAA Safety Briefing for oLar first experimental certificate, which we 

anticipate being issued shortly, Amazon was directed to seek ari exemption from several 

Federal Aviation Regulations to facilitate the oper- ation of our researcfi and developr-nent 

vehicles. Operations under this exemption will be conducted in strict accor-dance with the 

procedur- es and safeguards required by our experimerital certificates, as further -descr- ibed 

below. Such requir- emerits are at least as r- estrictive, and in many cases rnore restrictive, ttiari 

those that FAA has placed on comrrlercial small Lannianned aircraft systerns (sUAS) operators 

when granting exemptions from the ver- y sar-ne regulations from which Ariiazon now seeks 

r-elief. Due to the riatur-e of our request, we ask that this petition be grarited on an expeciited 

basis. 

P.O. BOX 812Z6, SEATTI E, WA 08108-1226 

V1lVVVIAMA'LON.COM 
FAA Dockets 

February 5, 2015 

Page 2 

Information Supporting this Petition as Specified in 14 C.F.R. § 11.81 

(a) Mailing address and other contact information such as a fax number, telephone 

number, or e-mail address 

Amazon.com 

Legal Department 

Re: Prime Air Experimenta) Certificate Exemption Petition 

440 Terry Ave. North 

Seattle, WA 98109 

Fax: 206-266-7010 

Email: prime-air-exemption@amazon.com 

(b) The specific section or sections of 14 C.F.R. from which Amazon seeks an exemption 

Amazon is seeking an exemption from the following provisions at the direction of 

the FAA team processing the application for our first experimental certificate: 

• 14 C. F. R. § 61.113 (a) an d(b) 

• 14 C. F. R. § 91.119(c) 

• 14 C. F. R. § 91.121 

• 14 C. F. R. § 91.151(a) 

(c) The extent of relief Amazon seeks, and the reason Amazon seeks the relief 

To ensure that our requested operations are as safe as possible, we plan to test on 

private Amazon property in a rural area of Washington State, away from people or crowds. We 

will do so under the supervision of trained pilots, at low altitudes, below 400 feet above ground 

level (AGL), within visual line of sight, and by employing "geofencing" technology and other 

robust safety measures that will keep the vehicle confined to the operating area. A copy of the 

Safety Checklist for what will be our first experimental certificated vehicle — which describes in 

further detail the safeguards that will be common to all test vehicles that will operate under the 

requested exemption — is attached as a confidential exhibit and is hereby incorporated by 

reference. Moreover, Amazon's test operations will only be conducted under the FAAapproved procedures and limitations associated with the experimental certificate for each of 

our vehicles. 
FAA Dockets 

February 5, 2015 

Page 3 

Against this backdrop, the specific relief Amazon seeks in this petition is as follows: 

• 14 C.F.R. § 61.113(a) and (b) — FAA has determined that pilots operating Amazon's 

vehicles under an experimental certificate would be acting as Pilot in Command (PIC) of 

an aircraft for compensation or hire because these operations would not be incidental 

to our business or employment. Amazon thus seeks an exemption to the extent 

necessary to utilize a pilot holding a private pilot certificate as PIC in our testing 

operations. In granting Section 333 exemptions to allow commercial sUAS operations, 

FAA relied on a detailed analysis of the sUAS operating environment and the private 

pilot aeronautical knowledge and airmanship requirements relative to those for 

commercial pilots. 1 That analysis applies equally, if not even more so, here since 

Amazon will not be conducting for-hire operations to the general public under this 

exemption. Further, our PICs will meet the qualification and currency requirements FAA 

prescribes in the experimental certificate for each of our vehicles. 

• 14 C.F.R. § 91.119(c) — Consistent with the relief provided to other sUAS operators, 

Amazon requires an exemption to the extent necessary to operate below an altitude of 

500 feet AGL and closer than 500 feet to any person, vessel or structure. 2 And at no 

point will any non-participating persons — whom will be strictly limited to Amazon 

employees, contractors and invitees — be closer than within 200 feet of flight 

operations. 

• 14 C.F.R. § 91.121 — Like other sUAS operators flying at similarly low altitudes that have 

been granted an exemption from this provision, our vehicles will use a barometric 

altimeter with GPS-derived altitude capabilities. 3 Amazon thus requests relief from the 

requirement to have a typical barometric altimeter aboard the vehicle to the extent it is 

necessary for us to report altitude to ATC in feet AGL. 

• 14 C.F.R. § 91.151(a) — As is the case with other sUAS operators that have been 

granted an exemption from this provision, the capabilities of our vehicles and short 

duration of our flight operations require relief from the prescribed minimums. 4 Our 

procedures also require us to monitor battery power levels and safely terminate the 

flight operation when the remaining battery capacity is at or below 20%. 

1 See, e.g., In the Matter of the Petition of Astraeus Aerial, Grant of Exemption No. 11062 (Sep. 25, 2014), Docket 

No. FAA-2014-0352, at 15-18. 

2See, e.g., In the Matter of the Petition of Team 5, LLC, Grant of Exemption No. 11158 (Jan. 29, 2015), Docket No. 

FAA-2014-0783, at 16-17. 

3See, e. g., id., a t 17. 

4 See, e.g., id. 
FAA Dockets 

February 5, 2015 

Page 4 

(d) The reasons why granfing /Irnazorn`s r•equesi woulcl be in rLhe public irnterest; thai is, I1ow 

it woii/d bene}`it the public (is a whole 

The outdoor- testing operations we seek in our petition for- exemption are a necessary 

stel) towards realizing the consLarTier- benefits of Pr- ime Air- , as well as a step in unlocking the 

enormous potential of sUAS technology. Aer- ial delivery is poised riiake goods available to 

consur-ners in a riianner that is riior- e environmentally-fr- iendly than current surface delivery 

rnethods, while impr- ovirig the overall safety of the trarisportation system. It is also in the public 

inter-est for Amazon to keep its sUAS R&D operations in the United States, and help Arnerica 

establish itself as tfie leader- iri developrnent of UAS technology. 

(e) TFie r•easons why granting fhe exernption would noa< adversely affecf safefy, or how the 

exernption would provide a level of safety at least eclual to fhat provided by fhe rule 

frorn which Arnazon seeks the exemption 

The requested exemption will not adversely affect safety because it will sirnply allow 

Amazon to operate in accordance with the FAA-prescribed procedures and safeguards 

associateci witli the experimental certificate for each of oLar veliicles. Mor -eover- , FAA has 

already deter- rnined on nearly 25 occasions that commercial sUAS operations conducted with 

r- elief fr-om these same requir- ements would not adversely affect safety and/or would provide an 

equivalent level of safety to the rules that would be other-wise applicable. 

(f) A summary FAA can publish in the Fg®ERAL REG1STE'R, stating: (1) 7'he rule from which 

Amazon seelcs the exemption; and (2) A brief description of the nature of the exemption 

Arnazon seel(s 

Amazon rnaintains that this petition for exer-nption does not require FAA to seek public 

comment because ther-e is good cause for the agency not to delay action pursuant to the 

~ criter- ia set forth in 14 C.F.R. § 11.87. 5 Gr- anting Amazon's petition will not set a precedent. FAA 

~

has now granted at least two dozen petitions for substantively identical relief to commercial 

~ sUAS oper- ator-s that make their ser- vices available to the gener - al public. 6 Delaying action on 

~ Amazon's petition would continue to prevent Amazon from testing outdoors in the United 

- States and cr- eating the key jobs and economic benefits that will come as a result. This petition 

is also timely, as it follows shortly after the FAA Safety Br- iefing on Amazon's first experimental 

certificate application. 

5 See, e.g., !n the Matter of the Petition of Lockheed Martin Corpor-ation, Grant of Exeniption No. 10673 (Dec. 14, 

2012), Docket No. FAA-2012-0819. 

6 See, e.g., Grant of Exemption No. 11158. 
FAA Dockets 

February 5, 2015 

Page 5 

(g) Any adclitioncrl inforrnaa~ion, views ol -cir-gurnents availcrble fio support Flmazon's reqtresi 

Please see the introductiori to this petition for - exemption. 

(h) If Fl mazon wants f o exercise the privileges of irts exempfion outside of ihe United Sfates, 

fihe reason why if needs to clo so. 

The research and developrnent operations described in this exemption r - equest will be 

conducted wholly within the United States. 

Arnazon urges the FAA to swiftly approve this petition for exemption so that we can 

continue our r- esear- ch and developmerit efforts for- Pr- ime Air outdoors in the United States. 

Please do not hesitate to contact me via email at prime-air-exer-nptionParnazon.corrr if 

you have any questions or concerns. 

Respectfully submitted, 

Stephanie Burns 

Associate General Counsel 

Amazon Prime Air