Maritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

1 September 21 , 2015



### From:

Dan Danay Airmada Inc.

To:

U.S. Department of Transportation, Docket Operations R oom W12

- 140 of the west building G round floor 1200 New Jersey Avenue

, SE

. Washington, DC, 20590

PETITION FOR EXEMPTION OF: Airmada Inc. FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS PART 21, SUBPART H AND SECTIONS §§ 45.23(b), 61.113(a) & (b), 91.103, 91.109, 91.7(a), 91.109

, 91.119

, 91.121, 91.151 (a) & (b),

91.203(a) & (b), 91 .40 5, 91.4 0 7 (a) (1), 91.409(a) (2), 91.417(a) & (b)

CONCERNING COMMERCIAL OPERATION OF ALIGN 690L AND FIREFLY6 UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)Maritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

2 

## TABLE OF CONTENTS

GLOSSARY OF ABBREVIATIONS

................................ ................................ ................................ .......... 3

SUMMARY

................................ ................................ ................................ ................................ .................. 4

INTRODUCTION AND INTERESTS OF THE PETITIONER

................................ ................................ .. 4
UNMANED AIRCRAFT SYSTEMS: ALIGN M690L, FIREFLY6

................................ ........................... 5

BASIS FOR OUR PETITION

................................ ................................ ................................ ...................... 5

CONDITIONS AND LIMITATIONS

................................ ................................ ................................ .......... 7

SECTIONS OF 14 C.F.R FROM WHICH AIRMADA INC. SEEKS EXEMPTION

............................... 10

PUBLIC INTEREST

................................ ................................ ................................ ................................ .. 14
EQUIVALENT LEVEL OF SAFETY

................................ ................................ ................................ ....... 14

PRIVACY

................................ ................................ ................................ ................................ ................... 15

NATIONAL SECURITY

................................ ................................ ................................ ........................... 15

Exhibit A

– Align M690L SPECIFICATIONS

................................ ............ שגיאה ! מוגדרת אינה הסימניה

. Exhibit B

– BIRDSEYEVIEW FireFLY6 SPECIFICATIONS

.................... שגיאה ! מוגדרת אינה הסימניה

.Maritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

3 

## GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AIM Aeronautic Information Manual

ATO Air Traffic Organization

CFR Code of Federal Regulations

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FPV First Person Video

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot i n Command

Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Sect ion 333

SO Safety Observer

s UAS Small Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Si gh t

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and LandingMaritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

4 

## SUMMARY

Pursuant to Section 333 of the F AA Modernization and Reform Act of 2012 ( T he Reform Act), and 14

C.F.R. Part 11, Airmada Inc. a maritime service provider

, hereby applies for an exemption from the FARs
listed below to allow operation of sUAS commercially in airspace regulated by the FAA s o long as such
operations are conducted with and under the conditions outlined herein or as may be established by the
FAA as required by Section 333.

The requested exemption would permit Airmada Inc. to pursue its commercial interests in providing

service s to clients using sUAV in the following areas:

1. First response

2. Inspection

3. Surveillance



## INTRODUCTION AND INTERESTS OF THE PETITIONER

Airmada Inc. is a maritime service provider. The company inspect s vessels and ports from the sky and
compliment s traditio nal patrol boat use s. By utilizing sUAS, cost s and operation hours of traditional

resources are substantially reduced

. The company’s objective is to conduct aerial photograp hy and
videography, in order to provide high quality digital imaging and video cont ent. The content would then
be used by port authorities, shipping companies, maritime agents, se arch and rescue missions, etc.

More specifically, Airmada Inc. ’s aerial video and photography operations will serve in the following

area s :

 Aerial survey of p orts / shipping yards

 Aerial survey of individual ships / boats

 Aerial videography to assist port authorities with maritime law enforcement

 Maritime situational awareness and first response missions, conducted by port authorities.Maritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

5 

## U NMANED AIRCRAFT S YST EMS : ALIGN M690L, FIREFLY6

Airmada Inc. seeks an exemption to operate Align and BIRDSEYEVIEW drones for compensation or

hire within the NAS . The Align M690L and BIRDSEYEVIEW FireFLY6 are VTOL sUAS with a GCS.

The Align M690L has a maximum gross weight of approximately 15 pounds

, 87.5 cm in length, 4 4.6 cm in length and a maximum speed of 15 meter/second ( See Exhibit A ) . The FireFLY6 has a maximum gross
weight of approximately 9 pounds , 95 cm in length

, 152 cm of wingspan and a maximum speed of 26

meter/sec ond. Both platforms are driven by six lithium p olymer battery powered electric motors ( See

Exhibit B )

.



## BASIS FOR OUR PETITION

Airmada Inc. is petitioning for an exemption to operate an Align M 690L and FireFLY6 with high

definition camera gear and GPS

- enab led safety features. These sUAS are operated by one GCS that
provides instrumentation data of the aircraft and FPV

. Using the GCS, one can set limits on: T he altitude

the sUAV flies AGL

. T he radius of the distance it flies from the operator

. The GCS also a llow s excluding

the sUAV from flight within designated Class B, C and D airspace including a no

- fly zone feature.

Both the Align M 690L and FIREFLY6 have a failsafe function that is triggered in the event

communication is lost between the sUAS and the mai n controller transmitter (in the GCS) . At that time,
the sUAS will return to its point of takeoff and land safe l y. If the communication is restored, the PIC is

able to regain control of flight and land manually. Additionally there is a failsafe function th at triggers

when the lithium

- polymer battery falls below an operator specified state of charge. In this case the drone
will also return to its point of takeoff and land safely. The minimum state of charge is set to 60% to allow
the drone sufficient energy to return from any phase of its mission.Maritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

6 In addition to th e safety features built into the referred sUAS and GCS , Airmada Inc. a company founded
by former naval officer and Space X avionics engineer and launch control operator , has a high bar of
safety ope rational standards. Every f light conducted by Airmada Inc. is performed in accordance to a
written procedure and a checklist. This ensures that all safety features, configurations and equipment has

been enable d , and all pers onnel onsite are informed and br iefed

.

The fact that the PIC holds an FAA Private Pilot license demonstrates Airmada Inc.’s high regard for safe
operations with an understanding of FARs, preflight inspections, knowledge of operations and differences
in airspace Classifications, maintena nce and repair, as well as being trained to high safety standards.

Under the requested exemption, Airmada Inc. ensures all operators have completed sUAS education and
training programs including all applicable regulations and guidance documents; includin g aeronautical
background information such as charts, NOTAM and a ircraft c irculars, r adio c ommunications p rocedures,

h uman f actors and c rew r esource m anagement, b asic sUAS Aerodynamics, w eather factors, and

a irmanship and d ecision

- making and s afe o peration s p rocedures

.Maritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

7 

## CONDITIONS AND LIMITATIONS

As the operator of these aircraft, Airmada Inc. is committed to the following conditions and limitations on
its operations. Airmada Inc. understands that failure to comply will be grounds for the immediate

suspens ion or rescission any exemption granted.

1. Operations are limited to the s UAS stated above when weighing less than 55 pounds including
payload.

2. The aircraft will not be operated at a speed exceeding 87 knots (100 miles per hour). In no case

will the aircraft be operated at airspeeds greater than the maximum aircraft operating airspeed
recommended by the aircraft manufacturer.

3. The aircraft will be operated at an altitude of no more than 400 feet AGL. Altitude must be
reported in feet AGL.

4. The aircraft will be operated within VLOS of the PIC at all times. This requires the PIC to be
able to use human vision unaided by any device other than corrective lenses, as specified on the

PIC’s U.S. driver’s license.

5. All operations will utilize a SO . The aircraft will be operated within the VLOS of the PIC and

SO at all times.

6. All operating documents needed to operate the s UAS will be accessible during flight operations

and made available to the a dministrator upon request. The operator will also present updated and

revise d documents if it petitions for extension or amendment.

7. Any s UAS that has undergone maintenance or alterations that affect the s UAS operation or flight
characteristics, e.g. replacement of a flight critical component, will undergo a functional test
flight prior to conducting further operations. This is explicitly codified in Airmada Inc.’s drone

maintenance manual.

8. Airmada Inc. is responsible for maintaining and inspecting the s UAS to ensure that it is in a
condition for safe operation.Maritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

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

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

10. Airmada Inc. will follow the s UAS manufacturer’s maintenance, overhaul, replacement,
inspection, and life limit requirements for the aircraft and airc raft components.

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

12. The PIC will hold a s UAS flight training certificate, in some cases training directly from the
aircraft manufacturer, and a valid U.S. driver’s l icense issued by a state, the District of
Columbia, Puerto Rico, a territory, a possession, or the Federal government.

13. Airmada Inc. will not permit any PIC to operate unless the PIC demonstrates the ability to safely
operate the s UAS in a manner consisten t with how the s UAS will be operated to acquire aerial
data, including evasive and emergency maneuvers and maintaining appropriate distances from
persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be
logged in a man ner consistent with 14 CFR § 61.51(b). Airmada Inc. will operate flights for the
purposes of training Airmada Inc. PICs and SO s (training, proficiency, and experience building )
and determining the PIC’s ability to safely operate the s UAS.

14. The aircraft will not operate within 5 nautical miles of an airport reference point (ARP) as
denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an
ARP, the center of the airport symbol as denoted on the current FAA

- published aerona utical
chart, unless a letter of agreement with that airport’s management is obtained or otherwise
permitted by a COA.

15. The sUAV will not be operated less than 500 feet below or less than 2,000 feet horizontally from
a cloud or when visibility is less than 3 statute miles from the PIC.

16. If the s U AS loses communications the aircraft will return to a pre

- determined location.

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

18. The PIC will be prohibited from beginning a flight u nless (considering wind and forecast
weather conditions) there is enough available powe r for the aircraft to conduct the intended
operation and to operate after that for at least five minutes or with the reserve p ower recommended by the manufacturer if gre ater.Maritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

9 19. All operations shall be conducted in accordance with an ATO

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

20. Documents used by Airmada Inc. to ensure the safe operation and flight of the s UAS and any
documents required under 14 CFR §§ 91.9 and 91.203 will be available to the PIC at the GCS of

the s UAS any time the aircraft is operating.

21. The aircraft will remain clear and give way to all manned aviation operations and activities at all

times.

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

23. All flight operations will be conducted at least 500 feet from all nonparticipating persons,

vessels, vehicles, and structures unless: a. Barriers or structures a re present that sufficiently
protect nonparticipating persons from the aircraft or debris in the event of an accident; or b. The
owner/controller/operator of any vessels, vehicles or structures has granted permission for
operating closer to those objects a nd the PIC has made an assessment of the risk of operating
closer to those objects and determined that it does n ot present an undue hazard.

24. The PIC, SO , operator trainees or essential persons will not be considered nonparticipating

persons un der this exemp tion.

25. All operations conducted over private or controlled

- access property will be conducted with the
permission from the property owner/controller or authorized representative. Permission from
property owner/controller or authorized representative will be obtained for e ach flight to be

conducted.

26. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of
the operational area as defined by the applicable COA will be reported to the FAA's 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.Maritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

10 

## SECTIONS OF 14 C.F.R FROM WHICH AIRMADA INC. SEEKS EXEMPTION

14 C.F.R. (Format) Part 21 & Subpart H : Airworthiness certificates
Subpart H, establishes the procedural requirements for the issuance of airworthiness certificates as
required by FAR §91.203(a)(1). Given the size and limited operating area associated with the aircraft to

be utilized by Airmada Inc. , an exemption from Part 21 Subpart H meets the requirements of an
equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49
USC §44701(f)) and Section 333 of the Reform Act both authorize the F AA to exempt aircraft from the
requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational
capability and proximity to airports and populated areas of the particular s UAS. In all cases, an analysis

of these crit eria demonstrates that the s UAS operated without an airworthiness certificate, in the restricted
environment and under the conditions proposed, will be at least as safe, or safer, than a conventional
aircraft operating with an airworthiness certificate wit hout the restrictions and conditions proposed.

14 C.F.R. 45.23(b) : Marking of the aircraft
This regulation requires that certain experimental, provisionally certified aircraft, or light

- sport category

aircraft to be marked with letters between 2 inches an d 6 inches high “limited”, “restricted,” “light

- sport,”
“experimental,” or “provisional,” near each entrance to a cabin, cockpit or pilot station. Even though the

s UAS will have no airworthiness certificate, an exemption may be needed as the s UAS will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the

size of the s UAS, 2 inch lettering may be impossible. Airmada Inc. will mark the s UAS as practicable.

14 C.F.R. 61.113(a) & (b) : Private pilot pr ivileges and limitations: Pilot in command
Sections 61.113(a) and (b) limit private pilots to non

- commercial operations. Because the sUAS will not
carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current

op erations by requiring the pilot operating the aircraft to have completed a sUAS flight

- training course.
Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled. The
area of operation is controlled and restricte d, and all flights are planned and coordinated in advance. TheMaritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

11 risks associated with the operation of the sUAS are so diminished from the level of risk associated with
commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as requested exceeds the present level of safety achieved by 14 CFR 61.113(a) and (b).

14 C.F.R. 91.7(a) : Civil aircraft airworthiness
The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As

the re will be no airworthiness certificate issued for the aircraft Airmada Inc. contemplates operating,
should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness.
Given the size of the aircraft and the operational r estrictions put on the aircraft, an equivalent level of
safety will be provided.

14 C.F.R. 91.9(b) (2) : Civil aircraft flight manual, marking and placard requirements

The sUAS , given its size and configuration has no ability or place to carry such a fligh t manual on the
aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such
an item on the aircraft. The equivalent level of safety will be maintained by keeping the Operating
Manuals at the ground control point where the pilot flying the sUAS will have immediate access to it.

14 CFR 91.103: Preflight action
This regulation requires the PIC take certain actions before each flight to ensure the safety of flight. An
exemption is needed from this requirement, as the pilot will take separate preflight actions, including
checking for weather conditions, checking flight battery or fuel requirements, checking takeoff and
landing distances, and all other actions in the Operating Manual and safety checklists. These actions will
provide an equivalent level of safety.

14 C.F.R. 91.109 : Flight instruction
Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is
being used for flight instruction unless that aircraft has fully functioning dual controls. By design, sUAS
do not have fully functional dual controls. Flight control is accomplished through the use of a GCS that

communicates with the aircraft via radio communications

. The equivalent level of safety is provided byMaritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

12 the fact that neither a pilot nor passengers will be carried in the aircraft, the ability to control the sUAS
via radio signals from the controller is unaffected by the size and speed of the aircraft.

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

Section 91. 119 establishes safe altitudes for operation of civil aircraft. The sUAS will never operate at
altitude higher than 400 AGL and all operations will occur during d aylight hours under VMC on ly.
The equivalent level of safety will be achieved given the size , weight and speed of the sUAS as well as
the location where it is operated. No flight will be taken without the permission of the property owner.
Because advance notice to the property owner and any onsite personnel, as well as the precautions

outlined be low, all affected individuals will be aware of the planned flight operations. Flight operations

will be conducted at least 500 feet from all non

- participating persons (persons other than the PIC or SO ),
vessels, vehicles and structures, unless operations d o not present an undue hazard. The sUAS will remain
within visual line of sight of the PIC or SO . Flight operations will be conducted at least 5 miles from an
airport. The PIC or SO will provide notification to the local Flight Standards District Office an d airport
controller of all operations within 5 miles of an airport. The FAA will have advance notice of all
operations through the filing of notices

- to

- airmen. Compared to flight operations with aircraft or
rotorcraft weighing far more than the sUAS propo sed herein, any risk associated with our operations is far
less than those presently presented with helicopters and other conventional aircraft operating at or below

500 feet AGL. In addition, the low

- altitude operations of the sUAS will ensure separation between these

sUAS operations and the operations of conventional aircraft that must comply with Section 91.119.

14 C.F.R. 91.121 : Altimeter Settings
This regulation requires each person operating the aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting a vailable
before departure.” T he sUAS will have a b arometric altimeter, in addition to a GPS altitude read out . An
equivalent level of safety will be achieved by the PIC confirming the altitude of the launch site shown on
the GPS altitude indicator before flight and comparing the reading to its barometer reading

.Maritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

13 14 C.F.R. 91.151(a) : Fuel requirements for flight in VFR conditions
Section 91.151(a) ou tlines fuel requirements for beginning a flight in VFR conditions. Relief from
Section 91.151(a)(1) is requested to the extent required to allow flights of a variety of sUAS during
daylight hours in VFR conditions to continue until 90 percent of remaining battery power or fuel reserves

remain. Airmada Inc. seeks the requested relief because without an exemption from Section 91.151(a)(1),
the flight time duration of the selected aircraft will be reduced and severely constrain the practicality of
any aerial a cquisition of data that Airmada Inc. proposes to conduct pursuant to this Petition.
The technical specifications of the proposed sUAS , their Operations Manuals, and Airmada Inc. ’s

pr oposed operating limitations, ensure that Airmada Inc. will safely operate the selected aircraft
during daylight hours in VFR conditions until 90 percent of remaining battery power or fuel

reserves remain.

14 C.F.R. 91.203(a) & (b) : Carrying civil aircraf t certification and registration

The sUAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. Therefore, there
is no ability or place to carry certification and registration documents or to display them on the sUAS . An
equivale nt level of safety will be achieved by keeping these documents at the ground control point where
the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the

sUAS

.

14 C.F.R. 91.405; 407 (a)(1); 409 (a)(2); 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 required inspections, except as provided in
paragraph (c) of this sec tion, 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, th ese sections will not apply to Airmada Inc

. Maintenance will b e accomplished pursuant to the user guide or operating m anual. An equivalent level of
safety will be achieved because these s UASs are limited in size and will carry a small payload and operate

o nly in restricted areas for limited periods of time. If mechanical issues arise, the s UAS can land
immediately and will be operating from no higher than 400 feet AGL. The PIC will ensure that the s UASMaritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

14 is in working order prior to initiating flight, perform required maintenance and keep a log of any
maintenance performed. Moreover, the PIC is the person most familiar with the aircraft and best suited to
maintain the aircraft in an airworthy condition to provide the equivalent level of safety.



## PUBLIC INTEREST Approval of exemptions allowing commercial operations of UASs for aerial acquisition of data enhances
safety while reducing risk. Manned aircraft in certain application create a greater risk because the aircraft
are much larger and carry an onboard human pilot. In contrast, a s UAS weighing 55 pounds or less will
carry no passengers or crew and, therefore, will not expose them to the risks associated with manned
aircraft flights. In addition, streams of aerial data will allow large commercial entities to m ake decisions
about how to best deploy ground resources and ensure the safety and cost

- effectiveness of their
operations.



## EQUIVALENT LEVEL OF SAFETY

Airmada Inc. proposes that the exemption requested herein apply to civil aircraft that have the

characteri stics and that operate within the limitations listed herein. These limitations provide for at least
an equivalent or even higher level of safety to operations under the current and proposed regulatory

structure.Maritime Drone Services 109 Kingston St. F l o o r 3

, A i r m a d a I n c

. c / o P r o j e c t 1 1 Boston, MA 02111 Phone: +1( 201 ) 637

- 1272 www.airmada. com Email: dan@airmada. com

15 

## PRIVACY

All flights will occur over priva te or controlled access property with the property owner’s prior consent
and knowledge. Images or video taken of individuals will have consented to being filmed or otherwise
they will be made anonymous.



## NATIONAL SECURITY

Given the small size of the s UAS i nvolved and the restricted environment within which they will operate,
our petition presents no national security issue.

We respectively request exemption under Section 333 to enable Airmada Inc. to operate efficient, limited,

low

- risk commercial sUAS ope rations for the activities stated respecting at all times the space and
privacy of citizens and property while keeping airspace safe.

Sincerely submitted,

Dan Danay

Dan Danay

109 Kingston St. F l o o r 3

, A i r m a d a I n c , c / o P r o j e c t 1 1 Boston, MA 02111 +1( 201 ) 637

- 1272