1 

### RED SPIDER Drone Consultants, LLC.

10409 Packer Drive

Wausau, WI. 54401

Robert E. Hughes

President/CEO

March 1 , 2016

U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, D.C. 20590

Re: Exemption Request Pursua nt to Section 333 of the FMRA and Part 11 of the

Federal Aviation Regulations, Seeking Exemption from 14 C.F.R. Part 21

Subpart H; 14 C.F.R. § 45.23(b); 14 C.F.R. § 45.27; 14 C.F.R. §§ 61.113(a) and

(b); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R . § 91.151(a); 14 C.F.R.

§ 91.405(a); 14 CF.R. § 91.407(a)(l); 14 C.F.R. §§ 91.409(a)(l ) and (2); 14

C.F.R. §§ 91.417(a) and (b)

.

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14

· C:F.R. Part 11, RED SPIDER Drone Consultants, LLC. ("Petitioner" or "RED SPIDER ")

herby applies for an exemption from the listed Federal Aviation Regulations ("FARs") and any

other necessary to allow its operation of small Unmanned Aircraft Systems ("UAS") to conduct

roo f inspections, tower inspections, real estate marketing, and agricultural areal surveys so

long as such operations are conducted within and under the conditions outlined herein. The

requested exemption would permit the operation of the UAS to obtain up

- clo se images of RED

SPIDER client policyholder ’ s roofs, towers and agricultural areas and perform an in

- depth

analysis of the images to determine the nature and extent of damage without placing claim

adjusters at risk. The RED SPIDER representative will be ab le to share promptly with the

claim representative and customer the report and inspection images and reduce claim payment

time.2 I. 

### REQUEST FOR EXEMPTION TO USE UAS FOR INSPECTION OF

INFRASTRUCTURE, REAL ESTATE AND PROPERTY MARKETING,

SPECIAL EVENT S

, SEARCH AND RESCUE, AND AGRICULTURAL

AREAL SURVEYS

A. Overview of Request to Use UAS for Inspection of Infrastructure

, R eal Estate and Property Marketing, Special Events, Search and Rescue,

and Agricultural Areal S urveys

RED SPIDER proposes to conduc t roof inspections, tower inspections, real estate and property

marketing, and agricultural areal surveys using small UAS including the DJI Phantom 3 Professional

and the DJI Phantom 3 Standard. As described more fully below, the requested exemption would

permit the operation of small UAS under controlled conditions in airspace that is I ) limited,

2) predetermined, and 3) controlled as to access. Operations will be limited to the customer's

property and always occur within the line of sight of the UAS operator. The property owner will

be notified in advance of the date and time for inspection. The customer's privacy and their

neighbors' privacy will be fully protected. RED SPIDER's use of UAS for inspection of i nfrastructure,

real estate and propert y marketing, special events, search and rescue, and agricultural areal s urveys

does not create a hazard to users of the national airspace or the publ ic or pose a threat to national

security.

Grant of this request is warranted, specific to inspection of i nfrastructure, as use of UAS will

improve safety for RED SPIDER's client claim representatives and customers . Currently, our

customer’s need to physic ally climb onto a roof, towers or high infrastructure using ladders for

inspection. Inspecting roofs and towers and high infrastructure is dangerous as evidenced by

annual industry wide worker compensation claims. Each year, claim handlers throughout the

industry are injured in falls while performing the task. By utilizing UAS, the claim handlers will

be able to reduce their exposure to hazards and obtain accurate assessments of the roof while

remaining safely on the ground.

B. Main Public Interest Benefits of Permitting Use of UAS for Inspection of

Infrastructure

Grant of RED SPIDER' s request to use UAS fo r roof, tower and high infrastructure inspections is in

the public interest. Inspection of roof, towers or high infrastructure conducted by human beings

carries with it certain risks. Currently, customers need to physically climb onto the roof using

ladder s and other safety gear to conduct inspections. Sometimes, a two

- story/ steep team is used,

requiring two inspectors and special safety harnesses. The dangers of inspecting any roof, towers or

high infrastructure include losing one's footing, having a ladde r slip, and being blown off a roof

from wind shear. A recent news article noted that fatalities rates among roofers and tower inspectors

are the highest in the construction trades. 1 In addition to safety concerns, inspecting a roof or tower

by physically c limbing on it has the potential to damage the roof. Using UAS for roof, towers or

high infrastructure avoids all of these risks. By utilizing UAS, RED SPIDER's customer will be able

to reduce their exposure to hazards and rapidly obtain accurate assessment s of the roof, towers or

high infrastructure while remaining safety on the ground. Faster roof, towers or high infrastructure

assessments will result in faster identification of potential need for repairs to avoid injury to

unsuspecting individuals and red uce the need to file claims in the event of an accident or damage to

the structure.

1 Alexandra Berzon and Kris Hudson, Fight Erupts Over Protecting Rooftop Workers, Wall Street Journal,

Sept. 28, 2014 available at http://online.wsj.com/articles/builders

- osha

- square

- off

- on

- rooftop

- safety

- 141 1947843.3 In addition, as described in more detail below, operation will not create a hazard to aviation or

the public. Flights will be conducted under 200 feet AGL

- avoiding interference with users of

the national airspace system. Operation will also not create a hazard to the public, as RED

SPIDER will only operate the UAS only over private property with the owner's conse nt. In

addition, the UAS will utilize waypoints and operational means around the owner's property

line to prevent the UAS from flying where it should not be. Finally, operation will not pose a

threat to national security. The UAS poses no credible threat t o national security due to its size,

speed, of operation, location of operation, lack of explosive materials or flammable jet fuels,

and inability to carry a substantial external load.



### II. THE FAA'S LEGAL AUTHORITY TO GRANT THIS EXEMPTION REQUEST

This exempt ion request will help the FAA to fulfill Congress' goal in pas sing Section 333 of the

FMRA. Section 333 directs the Secretary of Transportation to consider whether certain UAS may

operate safely in the national airspace system (NAS) before completion of t he rulemaking required

under Section 332 of the FMRA. The Secretary is required to determine which types of UAS do not

create a hazard to users of the NAS or the public or pose a threat to national security in light of the

UAS’s size , weight , speed , and op erational capability and whether operation will occur near

airports or populated areas and within the visual line of sight of the operator. 2 The

FMRA illustrates Congress' intent to have the FAA issue exemptions and allow civil UAS, so

long as they oper ate within the necessary safety parameters.

In addition, the Federal Aviation Act expressly grants the FAA the authority to issue exemptions.

This statutory authority by its terms includes exempting civil aircraft, as the term is defined

under § 40101 of the Act, which includes UAS, from the requirement that all civil aircraft must

have a current airworthiness certificate. The Administrator may grant an exemption from a

requirement of a regulation prescribed under §§ 44701(a) or (b) or in §§ 44702

- 44716 of the Act

if the Administrator finds the exemption in the public interest. 2



### III. APPLICATION INFORMATION

The name and address of the applicant is:

Robert E. Hughes

President /CEO

RED SPIDER Drone Consultants, LLC.

10409 Packer Drive

Wausau, WI. 54401

houseofhughes@ymail.com

708

- 945

- 2957

2 FAA Modernization and Reform Act of 2012, Pub. L. No. 112

- 95, 126 Stat. 75

- 76 (codified as a

Note to 49 

### u.s.c. § 40101).

3 49 U.S.C. § 44701(t). See also 49 U.S.C. § 4471 l (a); 49 U.S.C. § 44704; 14 C.F.R. § 91.203(a)(l ).4 Regulations from which the exemption is requested:

14 C.F.R. Part 21 Subpart

H; 14 C.F.R. § 45.23(b);

14 C.F.R. § 45.27;

14 C.F.R. §§ 61.113(a) and (b);

14 C.F.R. § 91.119(c);

14 C .F.R. § 91.121;

14 C.F.R. § 91.151(a);

14 C.F.R. § 91.405(a);

14 C.F.R. § 91.407(a)(l );

14 C.F.R. §§ 91.409(a)(l ) and (2);

14 C.F.R. §§ 91.417(a) and (b).



### IV. THE AIRCRAFT S

RED SPIDER specifically proposes to conduct UAS operations using small UAS includin g the

DJI Phantom 4, DJI Phantom 3 Professional and the DJI Phantom 3 Standard

.

The DJI Phantom 4 is a multi

- rotor aircraft with an approximate a 3.1 lbs. takeoff weight including

batteries, propellers and standard camera . The DJI Phantom 4 carries a 53 50 mAh LiPo 4S battery

, which

facilitates up to 28 minutes of flight time with standard payload. In addition, the DJI Phantom 4 has

incorporated into its system an optical sensing system. The system is capable of constantly scans for

obstacles in front of it, allowing it to avoid collisions by going around, over or hovering . The optical sensing

system can detect obstacles from a range of 2

– 49 feet. The minimum pixel size that the obstacle sensing

system can see is 500 pixels. T he DJI Phantom 4 has a maximum cruise speed of 20 m/s.

The DJI Phantom 3 Professional and the DJI Phantom 3 Standard are is a multi

- rotor aircraft. The DJI

Phantom 3 Professional and the DJI Phantom 3 Standard has approximately a 2.8 lbs. takeoff weight

including batteries, propellers and standard camera

. The DJI Phantom 3 Professional and the

DJI Phantom 3 Standard carries a 4480 mAh LiPo 4 S battery

, which facilitates up to 23 minutes of

flight time with standard payload. They can be flown with either a radio or tablet and carries a

variety of payloads. The DJI Phantom 3 Professional and the DJI Phantom 3 Standard has a maximum

cruise speed of 16 m/ s. They feature auto

- takeoff and landing, auto go home and landing , point

- of

- interest

and waypoint navigation.56 RED SPIDER agrees that any UAS it uses for inspection of i nfrastructure, real estate and property

m arketing, special events, search and r escue, and agricultural areal s urveys will inclu de, at minimum:

waypoints an d maximum ceiling of 200' AGL, flight programming capabilities, a flight termination

link available to the operator to prevent a "fly away," and safe abort procedures. If the UAS loses

communications or its GPS signal, the UAS will return to a pre

- deter mined location and land or be

recovered in accordance with the Operations Manual. The UAS will have markings identifying the

serial number and identification (N

- number) markings as large as practicable.

Further, RED SPIDER's UAS operation will comply wi th all manufacturer Safety Bulletins. Any UAS to

be used will weigh less than 55 pounds and would be specifically authorized by the FAA

. UAS operations

will occur only during daytime.



### V. OPERATING PARAMETERS

Petitioner proposes that the exemption request ed herein apply to civil aircraft that have the

characteristics and that operate with the limitations listed herein. These limitations provide for at

least an equivalent 'or even higher level of safety to operations under the current regulatory

structure b ecause the proposed operations represent a safety enhancement to the already safe

operations conducted with conventional aircraft. Further details about the aircraft and operating

procedures are available in the Operations Manual and Training Syllabus.

Th e limitations and conditions to which RED SPIDER agrees to be bound when conducting

commercial operations under an FAA issued exemption include :

A. UAS Pilot and Observer

1. UAS operations will be conducted by, at minimum, pilot and third

- class medical

certifi cation or sports pilot’s license and a valid U.S. driver’s license

.

2. All UAS operations must utilize a visual observer ("VO").

3. The pilot

- in

- command ("PIC") and VO must be able to communicate

verbally at all times.

4. The PIC will be wearing a safety vest th at identifies him or her as the pilot.

5. Prior to operations, the pilot must have accumulated and logged a minimum

of 200 flight cycles, or more as required by the FAA, and 25 hours of total

time as a UAS rotorcraft pilot. The pilot must also have accumulat ed and

logged prior to operations at least ten hours as a UAS pilot with a similar

UAS type (single blade or multi

- rotor). Prior documented flight experience

that was obtained in compliance with applicable regulations may satisfy this

requirement.

a. Trainin g, proficiency, and experience

- building flights can also be

conducted under the FAA' s grant of exemption to accomplish the required

flight cycles and flight time

.

b. During training, proficiency, and experience

- building flights, all persons

not essential fo r flight operations are considered nonparticipants, and the

pilot must operate the UA S with appropriate distance from

nonparticipants in accordance with 14

C.F.R. § 91.119.7 6. RED SPIDER will require all pilots conducting UAS operations to

provide proof of pilot and third

- class medical certification or sports pilot ’ s

license and a valid U.S. driver ’ s license.

B. Operational Parameters

1. Aircraft will not carry pilots or passengers, and aircraft will not carry

explosive materials or flammable liquid fuels.

2. U AS must be operated within visual line of sight of the pilot at all times.

3. UAS may not be flown at ground speeds exceeding 87 knots

. The UAS will

not be operated in excess of aircraft manufacture ’ s recommended maximum speed.

4. Flights will be operated at an altitude of no more than 200 feet above

ground level.

5. Each UAS opera tion will be completed within 18 minutes flight time or

with 25 % battery power remaining, whichever occurs first. At 20 % battery

the UAS will enter a return and land sequence; at 1 5 % it will land

immediately.

6. UAS will not be operated over any person (other than participating RED

SPIDER personnel) at an altitude that is hazardous to persons or property

on the surface in the event of a UAS failure or emergency.

a. Distance from participat ing persons will be specified in the

Operations Manual.

b. Operations will be conducted as far as practicable from

non -participating persons.

7. The UAS will abort the flight in the event of unpredicted obstacles or emergencies in

accordance with the Operation s Manual.8 

### 8. The operator must obtain an Air Traffic Organization (ATO) issued

Certificate of Waiver or Authorization (COA) prior to conducting any

operations under this grant of exemption.

a. This COA will also require the operator to request a Notice to

Air men (NOTAM) not more than 72 hours in advance, but not less

than 48 hours prior to the operation.

9. Operations will be limited to the property of consenting RED

SPIDER clients

.

10. Petitioner will display signage notifying the public of UAS operations

before b eginning operations. Signs will be approximately 18" x 24" in

size and will be placed in locations that will be visible from adjacent

roadways at least 5 minutes prior to UAS operations. An area will be

marked off as the UAS "landing zone." Petitioners will also display

signage notifying the public that UAS operation is in progress once

operations begin.

11. Before conducting operations, the radio frequency spectrum used for

operation and control of the UAS will comply with the FCC or other

appropriate gove rnment oversight agency requirements.

12. The documents required under 14 C.F.R. § 91.9 must be available to the

PIC at the Ground Control Station of the UAS any time the aircraft is

operating. These documents must be made available to the Administrator

or an y law enforcement official upon request.

13. The UAS must remain clear and yield the right of way to all other manned

operations and activities at all times (including, but not limited to, ultra

light vehicles, parachute activities, parasailing activities, ha ng gliders,

etc.).

14. RED SPIDER will ensure safety to first responder aircraft and

helicopter traffic. Upon notification from manned aircraft controllers

or through visual identification of manned aircraft, RED SPIDER

will immediately suspend the UAS flight until the airspace is cleared.

15. UAS operations may not be conducted during night, as defined in 14

C.F.R. § 1.1. All operations must be conducted under visual

meteorological conditions (VMC). Flights under special visual flight rules

(SVFR) are not author ized.

16. The UAS may not be operated by the PIC from any moving device or

vehicle.9 

### 17. The UAS may not be operated less than 500 feet below or less than 2,000

feet horizontally from a cloud or when visibility is less than 3 statute miles

from the PIC.

18. The U AS may not operate in Class B, C, or D airspace without approval

from the FAA. The UAS may not operate within 5 nautical miles of the

geographic center of a non

- towered airport as denoted on a current FAApublished aeronautical chart unless an agreement w ith that airport's

management is obtained, and the operation is conducted in accordance

with a NOTAM as required by the Operator's COA. The letter of

agreement with the airport management should be made available to the

Administrator upon request.

19. Altitud e information will be provided to the UAS pilot via a digitally

encoded telemetric data feed, which downlinks from the aircraft to a

ground

- based on

- screen display. The UAS may have a GPS altitude

readout. Prior to each flight, a zero altitude initiation p oint will be

established and confirmed for accuracy by the PIC.

20. Any incident, accident, or flight operation that transgresses the lateral or

vertical boundaries of the operational area as defined by the applicable COA

must be reported to the FAA's UAS Int egration 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.

Further flight operations may not be conducted until the incident, accident, or

transgression is reviewed by AFS

- 80 and authorization to resume operations is

provided.10 C. Operations Manual

1. The Operator must follow the procedures as outlined in its Operations

Manual, which is under develop ment at this time.

2. The Operations Manual must be maintained and made available to the

Administrator upon request.

D. Pre

- Flight Inspections and Maintenance

1. Prior to each flight, pilot will inspect UAS to ensure it is in condition for

safe flight. If the in spection reveals a discrepancy, aircraft will be

prohibited from operating until the necessary maintenance has been

performed and the UAS is found to be in a condition for safe flight.

2. All maintenance and alterations will be properly documented in the

air craft records.

3. Any UAS that undergoes maintenance or alterations that affect the UAS

operation or flight characteristics will undergo a functional flight test in

accordance with the Operations Manual.

4. Petitioner will institute a rigorous maintenance prog ram to ensure

airworthiness of UAS. Operator will follow the manufacturer's UAS

aircraft/component, maintenance, overhaul, replacement, inspection, and

life limit requirements

.

a. When unavailabl e, requirements will be established,

including for the followin g:

1. Actuators I Servos;

11. Transmission (single rotor);

111. Powerplant (motors);

1v. Propellers;

v. Electronic speed controller;11 v1. Batteries;

v11. Mechanical dynamic components (single rotor);

v111. Remote command and control;

1x. Ground co ntrol station (if used); and

x. Any other components as determined by the operator

.

5. Operator will develop procedures to document and maintain a record of the

UAS maintenance, preventative maintenance, alterations, status of

replacement/overhaul component parts, and the total time in service of the

UAS.



### VI. SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PETITIONERS SEEK AN

EXEMPTION

RED SPIDER requests exemption from the following Federal Aviation Regulations ("FARs") to

the extent necessary to enable the req uested UAS operations for the reasons detailed below.

A. 14 C.F.R. Part 21 Subpart H Airworthiness Certificates

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the

issuance of airworthiness certificates. Given the size and limited operating area associated with

the aircraft to be utilized, 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 4 and Sec tion 333 of the FMRA both authorize the FAA 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 UAS . In

all cases, an analysis of these criteria demonstrates that the UAS operated without an

airworthiness certificate, in the proposed environments and under the conditions proposed will

be at least as safe, or safer, than a conventional aircraft (fixed wi ng or rotorcraft) operating with

an airworthiness certificate without the restrictions and conditions proposed.

The DJI Phantom 3 Professional and the DJI Phantom 3 Standard UAS to be operated

hereunder are less than 15 pounds including payload, carries n either a pilot nor passenger,

carries no explosive materials or flammable liquid fuels, and will operate exclusively within the

parameters stated in the Operations Manual. Unlike other civil aircraft, operations under this

exemption will be tightly control led and monitored by both the operator and under the

requirements and in compliance with local public safety requirements, to provide security for

the area of operation. The FAA will have advance notice of all operations via notices to airmen

(NOTAMS). Fin ally, these UAS, as a result of their size, weight, speed,

4 49 

### u.s.c. § 44701(t).12 operational capability, and operation within visual line of sight do not create a hazard to users of

the national airspace system or the public or pose a threat t o national security.

B. 14 C.F.R. § 45.23(b) Display of marks; general; 14 C.F.R. § 45.27 Location of

marks; non

- fixed wing aircraft

Section 45.23(b) requires markings in letters not less than 2 inches nor more than 6 inches high

the words such as "limited, "restricted," and "experimental," as applicable. Section 45.27

requires that each operator of a rotorcraft must display on that rotorcraft horizontally on both

surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

Given the size o f the UAS, two

- inch lettering will not be feasible. The UAS will also have no

entrance to the cabin, cockpit, or pilot station on which the applicable words can be placed. An

equivalent level of safety will be achieved by having any required words displaye d on the aircraft,

as applicable, in letters of legible size, in a location where the pilot, observer, and others working

with the UAS will see the identification. The FAA has issued exemptions to § 45.23 in Exemptions

Nos. 10700, 8738 , 10167, 10167A

, a nd 11062 . The FAA issued an exemption to

45.27 in Exemption No. 8496B.

C. 14 C.F.R. § 61.l 13(a) and (b) Private pilot /Sports pilot privileges and limitations

Sections 61.113 (a) and (b) limit private/sports pilots to non

- commercial operations . Because th e

UAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level

of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s

license or sports pilot’s rather than a commercial pi lot's license to operate this small UAS. Unlike a

conventional aircraft that carries the pilot and passengers , the UAS is remotely controlled with no

living thing on board. The area of operation will be controlled and restricted. The level of safety

p rovid ed by the requirements exceeds that provided by a single individual holding a commercial

pilot’s certificate operating a conventional aircraft . The risks associated with the operation of the

UAS are so diminished from the level of risk associated with comm ercial operations contemplated

by Part 61 when drafted , that allowing operations of the UAS as requested with a private / sports

pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. § § 61.113 (a) and (b).

The FAA issued an exemption t o this regulation in Exemption No . 11062.

D. 14 C.F.R. § 91.119(c) Minimum safe altitudes over congested and other areas

Section 91.119(c) establishes safe altitudes for operation of civil aircraft over areas other than

congested areas. RED SPIDER requests relief from this section with respect to those

participating persons, vehicles, and structures dir ectly involved with the operations . The UAS

will never operate at higher than 200 AGL. It will be operated in a restricted area, where

buildings and people wi ll not be exposed to operations without their pre

- obtained consent or

notification of UAS operations . Relief from this provision is warranted, as operations will be

conducted with the safety provisions as previously outlined. The FAA issued an exemption t o

this regulation in Exemption No. 11062.

E. 14 C.F.R. § 91.121 Altimeter Settings13 This regulation requires each person operating an aircraft to maintain cruising altitude by reference

to an altimeter that is set "...to the elevation of the departure air port or an appropriate altimeter

setting available before departure." As the UAS may not have a barometric altimeter, but instead a

GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved

by the operator, pursuant to the Operations Manual, confirming the altitude of the launch site shown

on the GPS altitude indicator before flight. The FAA issued an exemption to this regulation in

Exemption No. 11062.

F. 14 C.F.R. § 91.151(a) Fuel requirements for flight in VFR condit ions

Section 91.151 (a) prohibits an individual from beginning "a flight in an airplane under VFR

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to

the first point of intended landing, and, assuming normal cruising speed

- (1) During the day, to fly

after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes."

Complying with the 30 minute reserve requirement in 14 C.F.R. § 91.151, would unnecessarily

limit the length of RE D SPIDER's UAS flights. The battery powering the DJI Phantom 3

Professional and the DJI Phantom 3 Standard provides approximately 23 minutes of flight time.

To meet the 30 minute reserve requirement in 14 C.F.R. § 91.151, UAS flights woul d be limited

to a pproximately 18 minutes in length. Given the limitations on the UAS' s proposed flight area

and the location of its proposed operations within a predetermined area, a longer time frame for

flight in daylight conditions is reasonable.

Operating the small U AS in a tightly controlled area where only personnel and property owners will be

present does not engender the type of risks that § 91.151(a) was intended to alleviate given the size

and speed of the small UAS. Additionally , limiting UAS flight minutes would reduce the utility of the

flights for the roof and tower inspections for which the exemption will be granted. RED SPIDER

believes that an equivalent level of safety can be achieved by limiting flights to 18 minutes or 25% of

battery power, whichever happens first. The FAA issued an exemption to this regulation in Exemption

No. 11062 and 10673

.

G. 14 C.F.R. § 91.405(a) Maintenance required; 14 C.F.R. § 91.407(a)(l ) Operation

after maintenance, preventive maintenance, rebuilding or alteration; 14 C.F.R

. §§

91.409(a)(l ) and (2) Inspections; 14 C.F.R. §§ 91.417(a) and (b) Maintenance

records

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 section, have discrepancies repaired as prescribed in part 43 of this chapter...,"

and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these

sections will not apply to the Petitioner. The operator pursuant to the manufactures requirements and

recommendations will accomplish maintenance . An equivalent level of safety will be achiev ed

because these small UAS are very limited in size and will carry a small payload and operate only in

restricted areas for limited periods of time. If mechanical issues arise, the UAS can land

immediately and will be operating from no h igher than 200 feet AGL. T he operator will ensure that

the UAS is in working order prior to initiating flight, perform required14 maintenance, and keep a log of any maintenance performed. Moreover, the operator 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. The FAA issued an exemption to these regulations in

Exemption No. 11062.

H. Such other relief as the FAA deems appropriate to enable the requested operations

RED SPID ER also requests exemption from such other FARs as the FAA deems appropriate to

enable the requested operations. If, during the effective dates of any Grant of Exemption issued

pursuant to this Petition, the FAA issues interim or final rules for small UAS , RED SPIDER

requests that it be relieved of the requirements of any conditions and limitations of said exemption

and allowed to comply with any less burdensome applicable regulations that may have become

effective.



### VII. SUMMARY TO BE PUBLISHED IN FEDERA L REGISTER

Petitioner: RED SPIDER Drone Consultants, LLC.

Sections of 14 C.F.R. Affected: Part 21 Subpart H; § 45.23(b); § 45.27; §§ 61.113(a) and (b); §

91.119(c); § 91.121; § 91.151(a); § 91.405(a); § 91.407(a)(l ); §§ 91.409(a)(l ) and (2); §§

91.417 (a) and (b).

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 C.F.R. Part 21

Subpart H; 14 C.F.R. § 21.191(a); 14 C.F.R. § 45.23(b); 14 C.F.R. § 45.27; 14 C.F.R. §§

61.113(a) and (b); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91 .121; 91.151(a); 14 C.F.R. § 91.405(a);

14 C.F.R. § 91.407(a)(l ); 14 C.F.R. §§ 91.409(a)(l ) and (2); 14 C.F.R. §§ 91.417(a) and (b) to

conduct small unmanned aircraft systems (UAS) roof inspections subject to operating procedures that

meet or exceed t hose that FAA requires for similar operations.



### VIII. CONCLUSION

Satisfaction of the criteria provided in Section 333 of the FMRA regarding size, weight, speed,

operating capabilities, proximity to airports and populated areas, operation within visual line of sight,

and national security, provide more than adequate justification for the grant of the requested

exemption allowing operation of Petitioner's UAS for roof inspections, t ow er i nspections, real estate

marketing, and agricultural areal s urveys

.15 NOTE:

Substantially similar exemptions have been recently granted by the FAA, including:

(1) Pelican Drones, LLC Exemption No. 11634 Regul atory Docket No. FAA

– 2015

– 0571

(2) Aero Photos E xemption No. 15019 Regulatory Docket No. FAA

– 2015

– 3681

(3) 323 Unmanned Flight Services LLC Exemption No. 15055 Regulatory Docket No. FAA

– 2015

–

6037

(4) Matthew Dutcher Exemption No. 15002 Regulatory Docket No. FAA

– 2015

– 6 113

(5) Jordan Leigh Wildlife Imagery Exemption No. 14992 Regulatory Docket No. FAA

– 2015

– 4392

(6) Drago Entertainment Inc Exemption No. 14971 Regulatory Docket No. FAA

– 2015

– 5048

(7) Drone University USA Exemption No. 14950 Regulatory Docket No. FAA

– 2015

– 3684

(8) John M Bu vala â Airfox Photography Exempt ion No. 14973 Regulatory Docket No. FAA

–

2015

– 5010

(9) Insight Aerial Concepts LLC Exemption No. 14960 Regulatory Docket No. FAA

– 2015

– 5451

(10) Rod Cambridge Exemption No. 14978 Regulatory Docket No. FAA

– 2015

– 3690

131 6