This petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. PO Box 4055 , Greenvill e, SC 29608 864.492.1648



### M3 Partners , LLC & White Top Unmanned Aircraft Systems (WT

- UAS)

Petition for Exemption
Title 14 Code of Federal Regulations (14 CFR)

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

FAA

- 2007

- 0001

March 17, 2015

Submitted by: Mr. Michael W. Middleton Mr. Marty J. Fisher President, M3 Partners, LLC Member, M3 Partners, LLC FAA Commercial Pilot Certificate xxx

- xx
- 4625 FAA Commercial Pilot Certificate xxx

- xx
- 2972This petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

.



### PETITION EXEMPTION REQUEST FROM M3 PARTNERS L LC, DOING BUSINESS AS WHITE TOP UNMANNED AIRCRAFT SYSTEMS (WT

- UAS)
M3 Partners LLC (herein referred to as M3 and also doing business as (DBA) White Top Unmanned Aircraft Systems WT

- UAS ) is requesting exemptio n from the Federal Aviation Administration (FAA) of the following: part 21, subpart H; and Sections 45.23(b), 61.113(a) and (b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), a nd 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR).



### INTRODUCTION AND INTERESTS OF THE PETITIONER

M3 Partners , LLC is a South Carolina limited liability corporation. We are a Service Disabled Veteran Owned Minority Small Business (SD V O MSB) formed in 2012 for the purpose of h elicopter /h elipad safety design and assessment and aviation support services . M3 is owned and operated by former Presidential helicopter p ilots and Helicopter Emerg ency Management Services (HEMS) p ilots who have seen the need for increased safety in the realm of helipad location, design and maintenance. The two principal members of M3, Mr. Martin Fisher and Mr. Michael Middleton are both Marine Corps veterans with over 40 years of aviation experience in the piloting, operations, and maintenance of aircraft in the United States and abroad. Mr. Fisher and Mr. Middleton are both FAA commercially rated airplane and rotorcraft

- helicopter pilots. Among their aviation c redentials both have served as White House Helicopter Aircaft Commanders (WHHAC) while serving at Marine Helicopter Squadron One (HMX

- 1) in support fhe President of the United States. Their responsibilities included the safe and timely transportation of t he President and the the coordination and safety of operations for HMX

- 1 missions domestically and internationally

. Mr. Fisher and Mr. Middleton bring a wide array of knowledge and experience in the areas of operational planning, airspace coordination, an d safety oversight that they are seeking to apply to the fledgling UAS sector.
The increase in helicopters, specifically HEMS and p olice helicopters thro u ghout the country has translate d in to an increase in take

- off and landings as well as pati ent transports to and from privately operated helipads

. A business need for a more standardized helipad and Emergency Landing Zone verification system was realized . M3 Partners has been working with hospitals, HEMS operators and fire d epartments to maximize safety in and around hospital helipads. M3 has also worked with local EMS and Fire and Rescue departments in order to establish and utilize predetermined (audited and safety documented) Emergency Landing Zones. M3's proprietary Heli pad Risk Register (HRR), procedures, and tools are assisting in standardizing and providing a quantitative non

- subjective evaluation and remedy for many of the privately owned and operated helipads. These helipads wil l greatly reduce the risk associated with a pilot landing in an unfamiliar environment. Our requested use of UAS’s will aid in the identifying and safely certifying ELZ and helipads for future HEMS and Police usage.
In the course of helipad work we have a lso routinely been asked to perform numerous real estate specific tasks. These requests have come from real estate and development professionals seeking someone with aviation experience that could operate a UAS in support ofThis petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. their businesses. Upon a mark et analysis, we have determined that out aviation experience, operational planning, and flight safety knowledge positions us to provide these services if we are allowed to do so within the current regulations. We also feel that our experience places us in unique position to assist in setting the “standard” for the safe employment of UAS’s at this initial stage of their inception for commercial use.

I. Helipad and Helicopter Interests of Petitioner:
Utilizing Turbine or piston helicopters to verify and land in ELZ is both costly and an ineffective use of assets. Operating turbine powered HEMS helicopters costs between $500 and $1500/hr. HEMS helicopters are also not be able to shoot video or photo’s as the crew is focused o n “eyes out”. Commercial helicopter video services costs are $500

- 1000/hr and require helicopters to fly low and hover at altitude’s that would require the aircraft to operate inside the dangerous Height

- Velocity curve of a helicopter

.
Unmanned A ircraft Systems ( UAS ) will b e able to safely video the landing zones and use that video to orient pilots and HEMS crews on the zones for future operations. UAS’s will also be able to identify hazards to hospital helipads which currently have no FAA regulations for certifications. UAS ’s are able to safely identify approach and departure routes based on safe obstacle avoidance. UAS’s will also be able to do this with little to no “noise pollution” to local residence, which is one of the chief complaints of residence who live close to h ospital helipads.

II. Real Estate Interests of Petitioner:
M3 Partners LLC has been in discussion with real estate and videography companies to integrate UAS operations into private real estate development, survey, assessment and filming. M3 will utilize UAS ’s to bring a more accurate and truer picture in the development, selling and buying of private property. M3 can use the small size UAS’s over private property to minimize any chance of damage to property or personnel. M3 will remain in the confines of spe cified and contracted private property to aid in the overall assessment of property. This enhanced look into property will benefit both the owner and potential buyer of properties as well as to give a more complete picture of the properties potential. This is currently done with large commercial property at great expense utilizing helicopters or fixed wing aircraft with multiple crewmembers, expensive cameras and both noise and fuel pollution

. M3 can bring this opportunity to smalle r private properties with a safe and economically advantageous systematic approach. Utilizing small UAS’s along with Pilot in Command and Visual Observer teams M3 will conduct safe, efficient, effective and revolutionary real estate services to companies a nd individuals. M3 will operate similar to a n “On Demand” FAR Part 135 carrier utilizing a General Operations Manual, as well as a Maintenance and Safety system . M3 will function as an integrated team utilizing the safe employ ment of small UAS’s in its commercial implementation.

Business development teams will effort and seek potential projects then work directly with the flight department

. Pilot in Command and Director of Safety will obtain, assess and plan a pr oject. This integrated approach will do so in a documented
, verifiable and safety consciousThis petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. manner. M3 PIC’s will all be FAA Commercially rated pilots working in conjunction with Visual Obse rvers to operate small UAS’s. Pre

- project planning will be discussed with business development and flight operations teams . Preflight assessment culminating in a mission briefing package, will be done by experienced pilots acting as PIC’s to add another l ayer of safety implementation. Final risk assessments will be signed off by a Director of Safety to verify compliance with company safety procedures as well as local, state and federal regulations. All flights will have two members in order to insure the safe outcome of each project. This integrated and layered approach exemplifies M3 Partners goal to only employ UAS’s in a responsible and safe manner. Please see the pr ovided “ M3 Partners UAS General Operations Manual ” for further details and more in

- depth implementation information

.

III. Conclusion Interests of Petitioner:
We believe the ability to operate UAS ’s in support of these business idea s will not only help economic growth in the forms of jobs but will increase the safety and awareness in the helicopter , HEMS, and real estate industr ies within the United States. The HEMS industry has been under scrutiny for years and this is another step that industry and government can take in order to affect a safer flying environment. The Real Estate industry will benefit through a more thorough “showing” process. Informed buyers will be more likely to target their time and

resourc es to homes and real estate that is more closely to their liking. Video obtained through UAS flights will create a more informed buyer, one who will be able to directed their time and efforts. There is also the potential for environmental savings by avoi ding pitfalls early on in the real estate development process that the use of UAS’s can aid in. The use of UAS’s can assist both developers and authorities having jurisdiction better understand the environmental and physical impacts of real estate develop ment projects.
As set forth in this Petition, M3 seeks to operate its Phantom 2+ UAS for the special purpose of aerial surveying, enhancing an established business model with increased safety and efficiency utilizing the highest sta ndards of operati ons and safety in the states of North Carolina, South Carolina, Georgia, Tennessee, and Virginia

.This petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. 

### UAS BACKGROUND INFO RMATION

DJI Phantom 2 Vision+ V3.0DJI Phantom 2 Vision+ V3.0 Unmanned information is provided for supplemental information. Th is UAS model will be our primary UAS vehicle to fulfill the commercial needs requested in this petition.

General Features

• Ready to Fly, Multifunctional Quad

- rotor System

• Custom ized H3

- 2D and H3

- 3D Gimbal Support

• Precision Flight and Stable Hovering

• 25min Flight Time & Smart Battery

• Auto Return

- to

- Home & Landing

• Advanced Power Management

• Intelligent Orientation Control (IOC)

• Easy Battery Replacement

• Self

- tightening Propeller

• Vide o Downlink Support

• CAN

- Bus Expansion Module

Aircraft

• Weight (Battery & Propellers Included) 1000g

• Hover Accuracy (Ready To Fly)This petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. o Vertical: 0.8m;

o Horizontal: 2.5m

• Max Yaw Angular Velocity 200°/s

• Max Tilt Angle 35°

• Max Ascent / Descent Speed

• Ascent: 6m/s; Des cent: 2m/s

• Max Flight Speed 15m/s(Not Recommended)

• Diagonal Length 350mm

• Flight Time 25mins

• Take

- Off Weight ≤ 1300g

• Operating Temperature

- 10°C ~ 50°C
Battery

• Supported Battery DJI Smart Battery

• 3S LiPo

• Capacity 5200mAh, 11.1V

• Charging Environment Range 0 °C to 40 °C

• Discharging Environment Range

- 20 °C to 50 °C
Remote Control & Operating Frequency

• 2.4GHz Remote Control

• Communication Distance (Open Area) 1000m

• Receiver Sensitivity (1%Per)

- 97dBm

• Working Current/Voltage 120 mA@3.7V

• Built

- In Lipo Battery Working Cu rrent/Capacity 3.7V, 2000mAh



### BASIS FOR PETITION

Petitioner, M3 Partners, LLC pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012, Section 333, Special Rules for Ce rtain Unmanned UAS Systems, hereby petitions the Administrator for an exemption from the requirements of 14 C.F.R. part 21, subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.103(b), 91.109, 91.119, 91.121, 91.151(a), 91.203(a) and (b), 91.405(a), 9 1.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR).
In the alternative, and in accordance with Federal Aviation Regulation (“FAR”) Section 21.16, entitled Special Conditions (14 C.F.R. § 21.16), M3 respectful ly requests that the Administrator prescribe special conditions for the intended operation of the UAS that contain such safety standards as the Administrator finds necessary to establish a level of safety equivalent to that established by the restricted ca tegory airworthiness certification standards specified in 14 C.F.R. § 21.185. In the alternative, M3 seeks an exemption from the requirement to have a certificate of airworthiness issued for its Phantom 2+ UAS, as otherwise contemplated by 14 C.F.R. Part 2 1.This petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. Below is an outline and description as to how M3 will responsibly and safely conduct UAS operations, based off the FAA Sep 2014 published guidelines.

I. Regarding UAS

1. Describe how UAS will be operated safely to minimize risk to NAS, persons and property on the ground

.

a. M3 will implement a tiered approval process before conducting any flights. Flights will be approved on an operation s level (they must be able to be completed within the prescribed company General Operations Manual and they must fit into the Safety Guidelines set forth by company Safety Policy)

b. M3 will operate a 2 person crew with Pilot in Command ( PIC ) as final operational control.

c. Flights will file a Risk Assessment Matrix prior to operations.

i. Weather will be obtained from an approved FAA w eather forecasting agency

ii. Flight path and plan will be digitally filed and briefed prior to flight

iii. UAS limitations will be briefed prior to flight

iv. Line of Sight limitations will be identified, mitigated and briefed

v. Vehicle safety features (return to home) will be tested prior to flight

vi. Emergency procedures and emergency action plans will be reviewed prior to approval

vii. (Insert vehicle specs addendum here)

d. Two tiered Operational control will be in place. Company Policy and Procedures and PIC final auth ority.

2. Describe procedures you would implement to ensure UAS is in condition for safe flight.

a. M3 will comply with all manufacture rs required and recommended maintenance procedures.

b. M3 will implement a digital maintenance tracking system to monitor and

rec ord all maintenance action items.

c. M3 will inspect the device in accordance to manufacture guidelines prior to each flight and post flight.This petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. d. The PIC will perform a company “preflight” before each flight. The PIC will also conduct a UAS conformity check bef ore conducting a flight operation

e. UAS flight manual and Maintenance and Inspection Manual added here

3. Describe the RF spectrum used for UAS control

.

a. Phantom 2 is already auth orized for flight not interfering with FAA RF spectrum usage.

II. Regarding the UAS PIC

4. Describe the qualifications required to perform as Pilot In Command ( PIC ) (who is directly responsible for the operation of the UAS. What would be the roles and qualificati ons of V isual O bserve r s (VO)

.

a. All PIC’s are at a minimum FAA Commercial Instrument Rotorcraft rated PICs with a minimum of 1,500 flight hours.

b. VO’s will have the same qualifications as PIC or will be an experienced UAS operator with a minimum of 50 flight hours controlling UAS . The VO’s primary role will be a “Second set” of eyes and safety observer for the PIC. VO’s will maintain sight of UAS as well as remain watchful for and hazards to UAS or personnel and property.

c. All PI C ’s and VO ’s will operate with standard aviation terminology regarding communication to flight operations.

d. All PIC’s and VO’s will log at least 1 flight within 30 days of pervious “flight for hire”

.

e. All PIC’s and VO’s will be required to pass a n annual written and flight exam conducted by M3 Partners Chief Pilot.

f. All PIC’s and VO’s flights will be logged digitally.

5. Medical standards of PIC

a. All PIC’s will hold at a minimum a class 2 medical certificate.

b. All M3 employee’s will participate in “Dru g Free” work place and comply with all appropriate FAR’s pertaining to Drug and Alcohol use.

III. Regarding the Operations of UAS

6. Describe the intended and proposed UAS operations. How you intend to provide a level of safety equivalent to that provided by the rule from which exemption is sought. Address plans to define operations boarders and procedures to ensure public safety. (Describe in petition or Operations Manual)This petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. a. M3 intends to utilize its UAS in the following procedures:

i. Helipad assessment

ii. Emergency Lan ding Zone certification

Real Estate

b. M3 will utilize approved FAA VFR sectionals and airspace classifications. In addition M3 will utilize GPS locations and Fore Flight software to pinpoint exact location in the NAS

c. M3 will operate the UAS no higher than 400’ AGL

d. M3 will operate the UAS on private property with the knowledge of said property owners

e. M3 will establish applicable NOTAMS with the local FSDO

f. M3 will display signage to provide warning of UAS in operation

g. M3 partners will utilize a VHF radio to monitor traffic as well as relay UAS specific operations during all operations

7. Provide specific UAS operations limitations regarding: Altitude, speed, minimum flight visibility, cloud clearances.

a. M3 will operate only in VFR conditions as defined by the FAA

b. M3 will operate within all airspace cloud clearances for the appropriate Class of airspace operating in (per FAR Part 91 cloud clearances)

c. M3 will not operate above 400’ AGL

d. M3 will not opera te the UAS greater than 30 knots

e. M3 will not fly UAS over any persons below 150’ AGL (with exception of PIC and VO)

8. Provide the characteristics of area intended for operations.

a. M3 will operate th e UAS in both “congested and non

- congested” area’s as defined by the FAA.

b. The “Return to H ome” feature of the UAS will be a safety feature utilized during all flight operations.

c. The UAS will be operated on private property. M3 will ask all potential personnel in the area to remain at least 150’ from UAS operation s . Personnel may also remain behind a stationary object. Due to the lightweight and smallThis petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. size of the UAS (less than 4 lbs) persons and property injury is unlikely b ut always remains a potential danger and will be mitigated through procedures, maintenance, and risk mitigation steps

.
d. M3 will utilize GPS locations along with “Google Earth” to annotate potential aerial obstructions during preplanning operations.

9. Petition should describe operations within close proximity of airports

a. M3 may receive operation request to perform aerial UAS fl ights in close proximity to airports. In these cases M3 will coordinate with the appropriate airport personnel to include local FSDO’s to obtain clearance to do so. NOTAMS will be issued. M3 will adjust flight profiles to remain well outside airport flight paths to include remaining outside approach and departure corridors as well as operating below fixed wing and rotary wing operating altitudes.

b. M3 partners will also operate a hand held VHF radio to monitor traffic as well as relay UAS specific operations, locations and altitudes. At any time communication is lost between the PIC and airport authorities the flight will be terminated.

c. M3 Partners primary business model is assessing and surveying hospital helipads/heliports in order to provide the safest operating environment. The UAS will be able to identify and capture obstructions that are not easily recognizable from the ground or from satellite imagery. M3 will operate UAS’s on and above various Helipads, Heliports and helicopter landing zones. M3 will only operate with the permission of Helipad/Heliport managers with proper notification and approval disseminated and received prior to flights. NOTA MS will be issue d along with communications with appropriate helicopter operators that utilize those Helipads/Heliports. M3 Partners will also be working with local government s to establish safe and acceptable “Emergency Landing Zones” for both routi ne HEMS flights and large scale disaster relief efforts.

10. Provide data in how company plans on remaining VLOS with UAS

.

a. M3 will operate with a minimum two person flight team, a PIC and VO. Both members will maintain VLOS with UAS at all times. PIC will be r esponsible for UAS and remain in sight at al l times, VO will act as a “second set of eyes” maintaining VLOS with UAS as well as “looking out” for potential hazards to flight. If at any time both personnel lose sight of UAS a “Return to Base” command will b e initialed and the UAS will proceed to its predetermined rendezvous location.This petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. 11. Provide Preflight safety risk assessment

.

a. R isk A ssessment M atrix (RAM) will be filled out and maintained electronically for all flights. RAM will be provided in Operations Man ual

12. Provide local FSDO when flights require coordination with outside agencies

a. M3 will notify and work with local FSDO any time a flight will operate in any airspace other than “Class G” Airspace as defined by FAR s

.
13. Must have Certificate of Authorization from FAA Air Traffic Organization prior to conducting operations in NAS.

a. M3 will work on COA with local FSDO’s upon FAA approval to operate UAS.



### M3 REQUESTS REFLIEF FROM THE FOLLOWING REGULATIONS

Part 21 pres cribes the procedural requirements for issuing and changing design approvals, productions approvals, airworthiness certificates, and airworthiness approvals.

§ Section 45.23(b) prescribes that when marks include only the Roman capital letter “N” and the reg istration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in let ters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable.
M3 Partners request relief from this regulation on the bas i s that the UA S is not of appropriate size to have 2 inch lettering on it that will enable it to be read unless UA S is stationary and on the ground. Marking for easy identification will be used in order to maintain visual contact

. . M3 will ma r k UAS with registration numb er to the largest extent possible.
Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy condition.

§ Section 91.7(b) prescribes that the pilot in command of a civil aircraft is responsible for determining wheth er that aircraft is in condition for safe flight and that the PIC shall discontinue the flight when airworthy mechanical, electrical, or structural conditions occur.

M3 Partners requests relief from this regulation on the bas i s that there is no FAA regulatory standard for determining the airworthiness of a UAS. M3 Partners will conduct preflight mission and maintenance inspection of UAS prior to any flight. Flights will be terminated and maintenance action initiated to troubleshoot and re pair UAS if the PIC decides at any time the UAS in not in a n safe for flight condition. Please refer to M3 Operations Manual for more specific policy and procedures.This petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. § Section 91.9(b)(2) prohibits opera tion of U.S.

- registered civil aircraft 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.

M3 Partners request s relief from this re gulation since there will be no pilots or passengers on board UAS and given its minimal size . M3 believes an equivalent level of safety will be achieved with the intent of this regulation by maintaining a safety/flight manual with the UAS PIC and VO

. M3 will use UAS operating manual s and any updates to satisfy the inten t of this regulation.

§ Section 91.103(b) prescribes that a pilot shall for any flight, become familiar with runway lengths at airports of intende d use, and takeoff and landing distance information.
M3 Partners requests relief from this regulation due to the nature of operating a UAS. Runways will not be used. M3 will conduct preflight planning using current s atellite imagery such as “Google Earth” and current VFR Sectionals for the area and routing to be flown . M3 will also do a “walk through” of the area to be flown to verify obstacles and hazards that may exist. Please refer to M3 Operations Manual for more specific policy and procedures.

§ Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:
(a) Anywhere. An altitude allowing, if a power unit fails, an emerge ncy landing without undue hazard to persons or property on the surface.
(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.
(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet t o any person, vessel, vehicle, or structure.
(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

— (1) A helicopter may be operated at less than the min imums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and
(2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.
M3 Partners requests relief from this regulation as it would detrimentally prohibit the commercial use of flyi ng UAS ’s for M3 Partners intended commercial applications

. Currently hospital helipad and Emergency LZ ’s are operated to and from “congested

areas ”. FAA Helipad circulars (A/C150.2C) gi ve recommended guidance to helipadThis petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. locations and flight paths but no regulation exist to enforce this and is “advisory ” only. Helicopter s routinely overfly homes, streets, parking lots business etc. on their approach and departure paths to a helipad or ELZ. M3 will be flying a small UAS (less than 3 pounds versus the 4,000 to 12,000 lb typical helicopter ) on the same flight paths in order to verify hazards and risks associated with operating in and out of such pads. In orde r to locate and map hazards that are not on VFR Sectional or identifiable from satellite imagery
, M3 PIC’s will have VHF radio’s and “monitor” 123.025 (as this is the common HEMS and “Helo Traffic Frequency) within the area it is working, in order to maint ain Situational Awareness with operating helicopters in the area. M3 will need to fly in certain locations that are currently considered “Congested”. M3 will not operate UAS ’s over or near open air assembl ies or large gatherings of person el

. M3 will cle ary display area’s where operations will be conducted, and will not conduct operations within 150 or persons not involved in flight operations.

M3 Partners intended use for real estate assessments will be done over private property

. Prior permission and risk mitigation as outlined earlier will be coordinated and consent granted with the property owner and other authorities having jurisdiction . M3 will mark the areas to be flown over and will not fly the UAS near individuals who are not involved with the flight survey. M3 will operate with two personnel ( PIC and VO ) which will enable M3 to “see and avoid” personnel and property hazards.
M3 will operate its UAS at an altitude of n o more tha n 4 00 feet AGL. Please refer to M3 Operations Manual for more specific policy and procedures.

§ Section 91.121 requires, in pertinent part, each person operating an 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 available before departure.”
M3 Partners requests relief from this regulation due to the UAS’s ability to use barometric and GPS derived altitude. AGL altitude will be used and UAS will remain below 4 00’ AGL at all times.

§ Section 91.151(a) prescribes that no person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enoug h 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
M3 Partners requests relief from this regulation due to the UAS ’s ability to only fly for 20

- 25 minutes with available battery life . M3 will plan flights no longer than 15 minutes before returning to change batteries. Along with the “Return to Home” safety feature (whic h will automatically return the UAS to a predetermined safety landing area, w e believe this will satisfy the “ inten t ” of th e regulation . The risk of fuel starvation (or total battery discharge) will be mitigated

. The UAS also has warning displays to i ndicate battery “life”. M3 will only operate during day time hours ( the hours between official sunrise and sunset ) and only in VFR conditions as defined in FAR Part 91

.This petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. § Section 91.203(a) prohib its, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States, the second copy of the Aircraft registration Application as provided for in 47.31(c).

§ Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft unless the airworthiness certificate or a special flight authorizati on issued under 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

M3 understands that this regulation does not pertain to its UAS operations based on recent decisions and that relief is not necessary

§ Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft inspected as prescribed in subpart E of the same part and shall, between required inspections, except as provided in pa ragraph (c) of the same section, have discrepancies repaired as prescri bed in part 43 of the chapter.

§ Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has undergone maintenance, preventive maintenance, rebuildi ng, or alteration unless it has been approved for return to service by a person authorized under § 43.7 of the same chapter.

§ Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calend ar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.

§ Section 91.417(a) and (b) prescribes, in pertinent part, that

— (a) Each registered owner or operator shall keep the followin g records for the periods specified in paragraph (b) of this section:
(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

— (i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completi on of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for return to service.
(2) Records containing the following information:This petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. (i) The total time in service of the airframe, each engine, each prop eller, and each rotor.
(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.
(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified t ime basis.
(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.
(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.
(vi) Cop ies of the forms prescribed by 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances.
(b) The owner or operator shall retain the following records for the periods prescribed:
(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.
(2) The records specified in paragraph (a)(2) of this section shall be reta ined and transferred with the aircraft at the time the aircraft is sold.
(3) A list of defects furnished to a reg istered owner or operator under 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.
M3 request relief from these regulation s with stipulation that M3 will operate and maintain UAS in compliance with manufactures operating instructions and M3 General Operations Manual guidelines. M3 General Operations Manual outlines the compa ny policy to track and verify maintenance on the UAS ’s , comply with pertinent FAA regulations and aviation industry “best practices” in order to operate safely and successfully

.This petition contains proprietary inf ormation of M3 Partners, LLC and White Top Unmanned Aircraft Systems ( WT

- UAS) . It is intended solely for the use of the FAA and its determination of this petition

. Such proprietary information may not be used, reproduced, or disclosed to any other parties for any other purpose without the expressed written permission of M3 Partners, LLC or White Top Unmanned Aircraft Systems ( WT

- UAS)

. 

### C ONCLUSION

In conclusion M3 Partners , LLC wishes to conduct UAS o perations for the commercial purpose of Helipad and Emergency Landing Zone “safety assessments” as well as private Real Estate assessments.

M3 Partners, LLC is a company with extensive civilian and military aviation knowle dg e and over 40 years of experience working within the NAS structure

.
All PIC ’s and company mechanics currently hold FAA certifications and work on a daily basis within the FAR’s that govern commercial flight and maintenance. Our management team has held numerous aviation department positions within the civilian and military aviation sectors to include departments of operations, maintenance, safety, standardization, and check pilot certifications

.
We hav e worked extensively to bring a robust safety management system (SMS) , proven aviation operations procedures, and risk mitigation steps into our proposed operations.
We strive to conduct UAS operations in a safe, legal and responsible manner.

It is our sincere belief that our extensive knowledge and experience will allow M3 Partners, LLC to operate UAS’s safely, legally, and responsibly and serve as a model for future UAS commercial operations

.