November 15, 2015 

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ScottAire Services, LLC

Contact: Garth R. Scott 5294 Viking Road Northeast Moses Lake, WA 98837 Email: Scottairepro@yahoo.com Phone: (406) 202-3797

U. S. Department ofTransportation Docket Operations West Building Ground Floor, Room w12-140 " 1200 NewJersey Avenue SE., Washington DC 20590



### Re: Exception Request Under Section 333 ofthe FAA Reform Act and part 11 ofthe Federal Aviation Regulations

Dear Sir or Madam: In pursuantto Section 333 ofthe FAA Modernization and Reform Act ofthe 2012 {reform act) and 14 CFR Part 11, 

### ScottAire Services, LLC, a**compc;~ny** that owns and operates Small Unmanned Aircraft Systems (UAS) requests to be exempted from the Federal Aviation Regulations (FAR) listed below so that 

### ScottAire Services, LLC may operate UAS commercially in airspace regulated bythe FAA, as long as here said operations are conducted within and under the conditions outlined herein oras may be established bythe FAA asrequired bysection 333.


### Company Background and Planned Operations ScottAire Services, LLCis aWashington based company owned by Garth R. Scott. Mr. Scott is a retired United States military officerwho presently holds a commercial rated helicopter instrument, airplane single engine rating with a current medical certificate and flight review with nearly 4000 hours oftotal flighttime. He is an experienced UAS pilot and is familiar with the operations and the maintenance ofthe hardware and software updates forthese systems. Our operations serves the public bycollection ofaerial imaging and data to enable inspections and assessment of industrial structures, agricultural management, surveys and photography of outdoor events along with videography (e.g. land and water based venues for imaging realestate, natural/scenic settings, outings, functions and events).


### Equivalent Level of Safety The requested exception would permitthe operation of lightweight (less than 7 lbs, total takeoffweight) UAS under controlled conditions for commercial use by a certified fixed wing, and rotorcraft pilotthereby enhancing safety and fulfillingthe Secretary ofTransportation's

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(the FAA Administrator's) responsibility to "establish requirements for safe operation ofsuch aircraft systems in national airspace systems", Section 333 (c) ofthe reform act. The enhanced safety using an UAS in comparison to manned aircraft, including helicopters ofsignificantly greater proportion and carrying crewmembers with flammable fuel is self-evident and beneficial to athe public interest, while being able to provide a commercially beneficial information and data more quickly, accurately, safely and economically with a significant less impacttothe environment. All operations will be performed with the public's safety and right to privacy safeguarded at all times.



### UAS Devices ScottAire Services, LLC UAS(s) are battery-powered, weighing well less than 7 pounds including the payload. At present, our UAS fleet will include the DJ1 Phantom Series and the DJ Inspire Series. The specific UAS(s) to be initially included in ourfleet:



### Parameter DJl Phantom 3 DJllnspire 1

Type 4 Prop RC Helicopter 4 Prop RC Helicopter Weight 2.71bs 6.471bs Flight Speed 29 knots 42 knots Flight Time 20min 18min Camera Integrated Integrated

The UAS(s) operate at speeds less than 50 knots and have the capabilityto hover and move in the vertical and horizontal planes simultaneously in a precisely controlled manner. ScottAire's primary intent is to utilize the UAS at much slower speeds for our imaging and data collection applications. As upgrades become available, we will incorporate more advanced systems in each series into ouroperations afterwe have reviewed new documentation and have trained to be capable and proficient with flying characteristics ofother UAS (s).


### Statutory Authority for Exemptions ScottAire Services, LLCsubmits this application in accordance with the Reform Act, 112 P.L. 95 331-334, and seeks relieffrom any current applicable FARs operatingthatwould prevent 

### ScottAire Services LLCfrom future commercial uses ofsmall UAS to operate in the national airspace system as described below. The reform Act section 332 provides for such integration ofcivil unmanned aircraft into our national airspace system as it is the public interestto do so. 

### ScottAire Services LLC's UAS(s) will meetthe definition of "small unmanned aircraft" as defined in Section 331 and therefore the integration ofthese UAS are expressly contemplated be the Reform Act. 

### ScottAire Services, LLCwould tike to operate its' light weight UAS(s) priortothe time period by which to Reform Act requires the FAA to promulgate rules governing such aircraft.

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The Reform Act directsthe Secretary,ofTransportation to consider whether certain unmanned aircraft systems may operate safely in national airspace before completion ofthe rule making required under Section 332 ofthe Reform Act. In makingthis determination, the Secretary of Transportation is required to determinewhich UAS do create a hazard to users ofthe national airspace system orthe public or pose athreatto national security in light ofthe following:

-The UAS size, speed, weight and operational capability
-Operation ofthe UAS in close proximityto airports and populated areas

- Operation ofthe UAS within visual line ofsight ofthe operator

Reform Act 333 (a). Ifthe secretary determinesthat such "vehicles" may operate safely in the National Airspace System, the secretary shall establish requirements forthe safe operation on national airspace.



### ScottAire Services, LLC utilizes multi-prop RC helicopters weighing less than 7 lbs that operate at speeds less than 50 knots and has the capabilityto hover and operate in thevertical and horizontal plane simultaneously in a precisely controlled manner. The UAS will operate onlythe visual line-of-sight (LOS) of the operator with a controlled flight area and only at 400 feet above ground level (AGL) or less. Most operations are envisioned at less than 100feet AGL. This operation will not present a hazard tothe national airspace system orto the public.

The very small nature ofthese UAS combined with the risk management presented belowwill allowforthe safe operation greaterthan that envisioned by Congress forthe FAA to establish and exemption allowing commercial operations ofthe UAS to commence immediately. Also due to the size of UAS and the controlled areas and low altitudes in which they will operate, approval ofthis exemption presents no national security issues and absolutely minimal safety concerns which have**be~n** mitigated through our risk management process. Given the clear direction given in Section 333 of the Reform Act, the authority contained the Federal Aviation Act, as amended, the strong equivalent level ofenhanced safety, reduced emissions utilizing UAS verses traditional aircraft as well as the economic impact of greatly reducingthe cost ofaerial data and imaging acquisition therebythe FAA grantthe requested the exemption without delay.

### Regulations For Exemption Request ScottAire Services LLC.. respectfully request the grant ofexemption to following specific sections totheTitle 14 Code of Federal regulations allowing itto operate lightweight UAS(s) for commercial use:


### Regulations: 14 CFR 21, subpart H/ AirWorthiness Certificates 14 CFR 45.23 (b)/Identification and Registration Marking 14 CFR 91.7(a)/Civil Aircraft Worthiness 14 CFR 91.9 (b) (2)/Civil aircraft flight manual, marking, and placard requirements 14 CFR 91.109/Fiight Instruction; Simulated instrumentflight and certain flighttest 14 CFR 91.119/Minimum safe altitudes 14 CFR 91.121/ Altimeter settings 14CFR 91.151 (a) Fuel requirements forflight in VFR conditions 14CFR 91.203 (a) 

### & (b) Civil Aircraft: Certifications required 14 CFR 91.405 (a) Maintenance required 14 CFR 91.407 (a)(l) Operation after maintenance preventive maintenance, rebuilding, or alteration 14CFR 91.409 (a) 

### & (b)/Inspections (Ifthere are any other CFRs not listed that need a request for exemption please feel free inform me)



### Operational Risk Management: Conditions and Limitations

The following are our proposed procedures and limitationsfortheflight operations ofScottAire Services, LLC. These guidelines and risk management procedure will be modified as such from recommendations provided be the FAA in concert with the submission ofthis timely request:

1. Flight will occur duringthe daytime hours. 2. Flights wil,l be operated in the visual line-of-sight (VLOS) ofthe Pilot in Command (PIC) and visual observer {VO) using vision with no supplemental devices otherthan corrective lenses. 3. Flight will be terminated at anytimethe weather and wind deteriorateto being "unsafe forflight"/based on manufactures recommendations and the PIC's experience. Operations will'followthe anticipated guidelines ofthis exemption (operations undervisual meteorologica,l conditions-VMC, and standard visual flight rules-VFR) 4. All documents, manuals and maintenance logs associated with the UAS will be present on the site ofoperations. In addition, the credentials ofthe PIC (pilot certificate, pilot logbookwith current flight review, current medical, and proper identification) will be available on site.5. The UAS will be assessed fgrairworthiness bythe PIC priorto each flight session using achecklistsubmitted by the manufacturers manual. All necessary calibrations and testing priortothe flight session will be performed. 6. The UAS will weigh less than 3 lbs/71bs respectively with speeds will less than 30/50 knots 7. Flight will be operated at 400feet AGL or less. 8. Crew will be a minimum ofthe PIC and VO/camera operator. The PIC will be responsible forflying the UAS and the monitoring its status and flight dynamics, while maintainingthe line ofsight and visualization and keepingthe system operations with the specified factory limits (flight range, battery power, etc). The VO will be involved in monitoringthe airspace for other aircraft, the ground for unintended vehicles and bystanders, and will also look for additional hazards that could compromise safe operations. 9. Operator (PIC) and crew includingVO will remain in voice contact duringthe entire flight operation. 

### 10. Priorto operations, weatherforecasts, weather radar, and air traffic patterns forthe
.area will be reviewed. The proximity ofthe intended location with respect to airports and rFRs will be determine using Foreflight software and all available information and flight service capabilities when possible. Ifoperations are anticipated within 5 nautical miles ofairport reference points, the airport management orAirTraffic Control (ATC) tower will be notified priortothe operation identifyingthe location, anticipated time, and the intent ofthe flight operations. When in the vicinity ofnon-towered airports, we will monitorairtraffic in the area and be able to informthem ofour operations as needed. 11. The UAS PIC will perform final check ofthe flight area and make certain ofthe safety all persons present and property in the controlled area priorto initiatingflight operations. 

### 12. All UAS will have the capabilityto return automaticallytothe operator in a safe
manner in the event ofthe lost RC communication or asystem problem. The auto return function will be checked and verified for proper operation on a regular**b;;~sis.** A starting GPS home-position will be established priorto each newflight. 13. The UAS will have indicators on the control and/or displays to inform the PIC ofthe UAS's distance away from the operator, its altitude and velocity, and its remaining battery power. 

### 14. Written and /or oral permission from the relevant property holders will be obtained when flights are conducted over private or controlled access property.



### Benefits to the Public as Whole
Approval ofthese 333 exemptions in general will allow commercial operations ofsmall UAS to provide a magnitude ofpublic services that we will all benefit from this imaging platform. Operating safely in the national airspace while serving public demands and reducing risk to life and limb is the overall goal on 

### ScottAire Services, LLC. Traditional aerial imaging requires large



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aircraft with flammable fuel flying in close proximityofcongested areas and people and often in less than optimal states ofpower in the height avoid areas at low altitudes. With the use of UAS, the risk of injuryofpeople on the ground orthe crew is greatly minimized in comparison tothe operation ofthe traditional aircraft. The granting ofthe use ofthese small UAS by 

### ScottAire Services LLC, will allow companies like ours to grow and provide employment and
career opportunities while enhancing safetythrough more efficient means ofaerial imaging. 

### ScottAire Services LLCJ believes in free enterprise and would offer assistance to other companies wishingto work collaborativelyto increase the safety and awareness ofhazards and threats to ourway ofliving.



### ScottAire Services LLCJ respectfully requests the FAA grant its exemption without delay. The FAA has the authorityto issue the exemption sought by 

### ScottAire Services LLC pursuanttothe Federal Aviation Act, 85 P.L. 726 {1958) as amended {the ACT}.

Please contact me if I can provide additional information and clarification to help expeditethe process.
Sincerely

Garth R. Scott ScottAire Services, LLC 5294 Viking Road Northeast Moses lake, WA 98837 Scottairepro@yahoo.com (406} 202-3797

Commercial Instrument Helicopter-Single Engine Fixed Wing Pilot Certificate Number: 3633289 {25 AUG 2015)