# ?**AII=IMRD~** Maritime Drone Services 109 Kingston St.
Phone: +1(201)637-1272 Floor 3, AinnadaInc. c/o Project 11 Boston, MA 02111 www.airmada.com Email: dan@airmada.com September 21, 2015



### From: DanDanay Ainnada Inc. To: U.S. Department ofTransportation, Docket Operations Room Wl2-140 ofthe west building Ground floor 1200 New Jersey Avenue, SE. Washington, DC, 20590

PETITION FOREXEMPTION OF: Airmada Inc. ; -.

- _l;

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# -- .. ;...·J

FORAN EXEMPTION SEEKING RELffiF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS PART 21, SUBPART HAND 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), 91.405, 91.407(a) (1), 91.409(a) (2), 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF ALIGN 690L ANDFIREFL Y6 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THEFAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112-95) 

### . ' <''"'

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1**··~·**Phone: +1(201)637-1272 

# ?**AIRMRD~** Maritime Drone Services 109 Kingston St. Floor 3, Ainnada Inc. c/o Project 11 Boston, MA 02111 www.airmada.com



## TABLE OF CONTENTS Email: dan@airmada.com

GLOSSARY OF ABBREVIATIONS
.......................................................................................................... 3 SUMMARY
..................................................................................................................................................4 INTRODUCTIONAND INTERESTS OF THE PETITIONER
..................................................................4 UNMANED AIRCRAFT SYSTEMS: ALIGN M690L, FIREFLY6
...........................................................5 BASIS FOR OURPETITION
......................................................................................................................5 CONDffiONS AND LIMITATIONS
..........................................................................................................7 SECTIONS OF 14 C.F.R FROMWHICH AIRMADA INC. SEEKS EXEMPTION
............................... 10 PUBLIC INTEREST
.................................................................................................................................. 14 EQUN ALENT LEVEL OF SAFETY
....................................................................................................... 14 PRIVACY
................................................................................................................................................... l5 NATIONAL SECURITY
........................................................................................................................... 15 ExhibitA Align M690L SPECIFICATIONS
............................................ .

### n,'T.:un ill'K il'lrl'Oil !ilK'.:l¥1 Exhibit B - BIRDSEYEVIEW FireFLY6 SPECIFICATIONS
.................... . 

### n,'T..tln ill'K il"lrl'Oil lilK'.:lW



### 2Phone: +1(201)637-1272

AGL 

### AIM ATO CFR COA FAA 

## FAR FPV' GCS GPS LOL NAS NOT AM PIC Section 

### 333 

# so sUAS VFR VLOS 

### VMC VTOL

# ~**AIRMRD~** MaritimeDrone Services 109 Kingston St. Floor 3, Ainnada Inc. c/o Project 11 Boston, MA 02111 www.airmada.com Email: dan@airmada.com


## GLOSSARY OF ABBREVIATIONS

Above Ground Level Aeronautic Information Manual AirTraffic Organization Code ofFederal Regulations Certificate ofAuthorization Federal Aviation Administration Federal Aviation Regulation First Person Video Ground Control Station Global Positioning System Loss ofLink National Airspace System Notice to Airman Pilot in Command FAA Modernization and Reform Act of2012 (FMRA) Section 

### 333 Safety Observer Small UnmannedAircraft System Visual FlightRules Visual Line ofSight Visual Meteorological Conditions Vertical TakeoffandLanding



### 3

# ~·**AIRMRD~** Maritime Drone Services 109 Kingston St.
Phone: +1(201)637-1272 Floor 3, AinnadaInc. c/o Project 11 Boston, MA 02111 www.airmada.com EmaD: dan@airmada.com


## SUMMARY Pursuantto Section 333 ofthe FAA Modernization and ReformAct of2012 (The ReformAct), and 14 C.F.R Part 11, Airmada Inc. a maritime service provider, hereby applies for an exemption from the FARs listedbelow to allow operation ofsUAS commercially in airspace regulatedby the FAA so long as such operations are conducted with and underthe conditions outlined herein or as may be establishedbythe FAA as required by Section 333.
The requested exemption would permit Airmada Inc. to pursue its commercial interests inproviding services to clients using sUA V in the following areas: 1. Firstresponse 2. Inspection 3. Surveillance 

## INTRODUCTION AND INTERESTS OF THE PETITIONER Airmada Inc. is a maritime service provider. The company inspects vessels and ports from the sky and compliments traditional patrol boatuses. Byutilizing sUAS, costs and operationhours oftraditional resources are substantially reduced. The company's objective is to conduct aerial photography and videography, in orderto provide high quality digital imaging and video content. The content would then beusedbyport authorities, shipping companies, maritime agents, search and rescue missions, etc.
More specifically, Airmada Inc.'s aerial video andphotography operations will serve in the following areas: • Aerial survey ofports 

### I shipping yards • Aerial survey ofindividual ships 

### Iboats • Aerial videography to assist port authorities with maritime law enforcement
• Maritime situational awareness and first response missions, conducted byport authorities. 4. 'Phone: +1(201)637-1272

# ~ AIRMRDJ:\ Maritime Drone Services 109 Kingston St. Floor 3, Airmada Inc. c/o Project 11 Boston, MA 02111 www.airmada.com Email: dan@airmada.com


## UNMANED AIRCRAFT SYSTEMS: ALIGN M690L, FIREFLY6
Ainnada Inc. seeks an exemptionto 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 M690Lhas a maximum gross weight ofapproximately 15 pounds, 87.5 emin length, 44.6 em in length and a maximum speed of 15 meter/second (See Exhibit A). The FireFLY6 has a maximum gross weight ofapproximately 9 pounds, 95 emin length, 152 em ofwingspan and a maximum·speed of26 meter/second. Both platforms are driven by six lithiumpolymer batterypowered electric motors (See Exhibit B). 

## BASIS FOR OUR PETITION
Ainnada Inc. is petitioning for an exemption to operate an Align M690L and FireFLY6 with high definition camera gear and GPS-enabled safety features. These sUAS are operatedby one GCS that provides instrumentation data ofthe aircraft and FPV. Using the GCS, one can set limits on: The altitude the sUAV flies AGL. The radius ofthe distance it flies from the operator. The GCS also allows excluding the sUA V from flight within designated Class B, C and D airspace including a no-fly zone feature.
Both the AlignM690L and FIREFL Y6 have a failsafe function that is triggered in the event communication is lost between the sUAS and the main controllertransmitter (in the GCS). Atthat time, the sUAS will return to its point oftakeoffand land safely. Ifthe communication is restored, the PIC is able toregain control offlight and land manually. Additionally there is a failsafe function that triggers when the lithium-polymerbattery falls below an operator specified state ofcharge. 

### Inthis case the drone will also return to its point oftakeoffand land safely. The minimum state ofcharge is set to 60% to allow the drone sufficient energy to return from any phase ofits mission.



### 5Phone: +1(201)637-1272

# ~·**AIRMRO~** Maritime Drone Services 109 Kingston St. Floor3, Ainnada Inc. c/o Project 11 Boston, MA 02111 www.airmada.com Email: dan@airmada.com In additionto the safety features built into the referred sUAS and GCS, Airmada Inc. a company founded byformer naval officer and SpaceX avionics engineer and launch control operator, has a high bar of safety operational standards. Every flight conductedbyAirmada Inc. is performed in accordance to a writtenprocedure and a checklist. This ensures that all safety features, configurations and equipment has beenenabled, and allpersonnel onsite are informed andbriefed.
The fact that the PIC holds an FAAPrivate Pilot license demonstrates Airmada Inc.'s highregard for safe operations with anunderstanding ofF ARs, preflight inspections, knowledge ofoperations and differences 

### inairspace Classifications, maintenance andrepair, as well as being trained to high safety standards.
Underthe requested exemption, Airmada Inc. ensures all operators have completed sUAS education and training programs including all applicable regulations and guidance docwnents; including aeronautical background information such as charts, NOT AM and aircraft circulars, radio communications procedures, human factors and crew resource management, basic sUAS Aerodynamics, weather factors, and airmanship anddecision-making and safe operations procedures.



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# ft AIRMROF\ Maritime Drone Services 1 09 Kingston St.
Phone: +1(201)637-1272 Floor 3, Ainnada Inc. c/o Project 11 Boston, MA 02111 www.airmada.com Email: dan@airmada.com


## CONDITIONS AND LIMITATIONS
As the operator ofthese aircraft, Airmada Inc. is committedto the following conditions and limitations on its operations. Ainnada Inc. understands that failure to comply willbe grounds for the immediate suspension orrescission any exemption granted. 1. Operations are limited to the sUAS 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 perhour). Inno case will the aircraft be operated at airspeeds greaterthan the maximum aircraft operating airspeed recommended bythe aircraft manufacturer. 3. The aircraft will be operated at an altitude ofno more than400 feet AGL. Altitude must be reported in feet AGL. 4. The aircraft will be operated within VLOS ofthe PIC at all times. This requires the PIC to be able to use human vision unaidedby any device otherthan corrective lenses, as specified onthe PIC's U.S. driver's license. 5. All operations will utilize a SO. The aircraft will be operated within the VLOS ofthe PIC and SO at all times. 6. All operating documents needed to operate the sUAS will be accessible during flight operations andmade available to the administrator upon request. The operator will also presentupdated and revised documents ifitpetitions for extension or amendment. 7. Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight characteristics, e.g. replacement ofa flight critical component, willundergo a functional test flight priorto conducting further operations. This is explicitly codified in AirmadaInc.'s drone maintenance manual. 8. Airmada Inc. is responsible for maintaining and inspecting the sUAS to ensure that it is in a condition for safe operation.



### 7

# ?**AIRMRD~** Maritime Drone Services 109 Kingston St.
Phone: +1(201)637-1272 Floor 3, Air:mada Inc. c/o Project 11 Boston, MA02111 www.airmada.com Email: dan@airmada.com 9. Priorto each flight, the PIC will conduct a pre-flight inspection and determine the sUAS is in a condition for safe flight. 10. Airmada Inc. will follow the sUAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components. 11. Each sUAS operatedunderthis exemption will comply with all manufacturer safety bulletins. 12. The PIC will hold a sUAS flight training certificate, in some cases training directly from the aircraft manufacturer, and a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, orthe Federal government. 13. AirmadaInc. will notpermit any PIC to operate unless the PIC demonstrates the ability to safely operate the sUAS in a manner consistent with how the sUAS 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 manner consistent with 14 CFR 

### § 61.51(b). Airmada Inc. will operate flights for the purposes oftraining AirmadaInc. PICs and SOs (training, proficiency, and experience building) and determining the PIC's ability to safely operate the sUAS. 14. The aircmft will not operate within 5 nautical miles ofan airport reference point (ARP) as denoted inthe current FAAAirport/Facility Directory (AFD) orfor airports not denoted with an ARP, the center ofthe airport symbol as denoted onthe current FAA-published aeronautical chart, unless a letter ofagreement with that airport's management is obtained orotherwise permitted by a COA. 15. The sUAV will not be opemted less than 500 feet below orless than 2,000 feet horizontally from a cloud orwhen visibility is less than 3 statute miles from the PIC. 16. Ifthe sUAS loses communications the aircraft will return to a pre-determined location. 17. The PIC will abort the flight in the event ofunpredicted obstacles or emergencies. 18. The PIC will beprohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available powerfor the aircraftto conductthe intended operation andto opemte after that for at least five minutes orwith the reserve power recommended bythe manufacturer ifgreater.


### 8

# ?

**AIRM~OP..** Maritime Drone Services 109 Kingston St.
Phone: +1(201)637-1272 Floor 3, Airmada Inc. c/o Project 11 Boston, MA 02111 www.airmada.com Email: dan@airmada.com 

### 19. All operations shall be conducted in accordance with an ATO -issued COA ifthe blanket COA does not cover the intended operation. 20. Documents used by Airmada Inc. 

### to ensure the safe operation and flight ofthe sUAS and any documents required under 14 CFR § § 91.9 and 91.203 will be available to the PIC at the GCS of the sUAS any time the aircraft is operating. 21. The aircraftwill remain clear and give way to all manned aviation operations and activities at all times. 22. The sUAS may be operatedby 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 are presentthat sufficiently protect nonparticipating persons from the aircraft ordebris in the event ofan accident; or b. The owner/controller/operator ofany vessels, vehicles or structures has grantedpermission for operating closerto those objects and the PIC has made an assessment ofthe risk ofoperating closer to those objects and determined that it does not present an undue hazard. 24. The PIC, SO, operatortrainees or essential persons will notbe considered nonparticipating persons under this exemption. 25. All operations conducted over private orcontrolled-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 each flight to be conducted. 26. Any incident, accident, or flight operationthat transgresses the lateral orvertical boundaries of the operational area as defmedbythe applicable COA will be reported to the FAA's sUAS Integration Office (AFS -80)

### within 24 hours. Accidents must bereported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

9

# ~**AIRMRD~** Maritime Drone Services 109 Kingston St.
Phone: +1(201)637-1272 Floor 3, Ainnada Inc. c/o Project 11 Boston, MA 02111 www.airmada.com Email: dan@airmada.com


## 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 ofairworthiness certificates as requiredbyFAR §91.203(a)(l). Given the size and limited operating area associated withthe aircraftto be utilized by Airmada Inc., an exemption from Part 21 Subpart H meets the requirements ofan equivalent level ofsafetyunderPart 

### 11 and Section 333 oftheReform Act. The Federal AviationAct (49 USC §4470l(f)) and Section 333 ofthe Reform Actboth authorize the FAAto exempt aircraft from the requirement for an airworthiness certificate, uponconsideration ofthe size, weight, speed, operational capability andproximity to airports andpopulated areas ofthe particular sUAS. In all cases, an analysis ofthese criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restricted environment andunderthe conditionsproposed, willbe at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without the restrictions and conditions proposed.
14 C.F.R. 45.23(b): Marking ofthe aircraft This regulation requires that certain experimental, provisionally certified aircraft, orlight-sport category aircraft to bemarked with letters between 2 inches and 6 inches high "limited", "restricted," "light-sport," "experimental," or "provisional," near each entrance to a cabin, cockpit orpilot station. Eventhoughthe sUAS will have no airworthiness certificate, an exemptionmay be needed as the sUAS will have no entrance to the cabin, cockpit orpilot station on which the word "Experimental" canbe placed. Giventhe size ofthe sUAS, 2 inch lettering may be impossible. Airmada Inc. will mark the sUAS as practicable.
14 C.F.R. 61.113{a) & {b): Private pilot privileges and limitations: Pilot in command Sections 61.113(a) and (b) limitprivate pilots to non-commercial operations. Because the sUAS will not carry a pilot orpassengers, the proposedoperations can achieve the equivalent level ofsafety ofcurrent operations byrequiring thepilot operating the aircraft to have completed a sUAS flight-training course. Unlike a conventional aircraft that carries thepilot and passengers, the sUAS is remotely controlled. The area ofoperation is controlled andrestricted, and all flights areplanned and coordinated in advance. The 10

# ~**AIRMRD~** Maritime Drone Services 1 09 Kingston St.
Phone: +1(201)637-1272 Floor 3, Airmada Inc. c/o Project 11 Boston, MA 02111 www.airmada.com Email: dan@airmada.com risks associated with the operation ofthe sUAS are so diminished from the level ofrisk associated with commercial operations contemplated by Part 61 when drafted, that allowing operations ofthe sUAS as requested exceeds the present level ofsafety 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 there will be no airworthiness certificate issued for the aircraft Airmada Inc. contemplates operating, should this exemption be granted, no FAAregulatory standard will exist for determining airworthiness. Given the size ofthe aircraft and the operational restrictions put onthe 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 orplace to carry such a flight manual onthe aircraft, not only because there is no pilot onboard, butbecause there is no room or capacity to carry such an item on the aircraft. The equivalent level ofsafety will be maintainedbykeeping 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 offlight. 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 takeoffand landing distances, and all other actions in the Operating Manual and safety checklists. These actions will provide an equivalent level ofsafety.
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 instructionunless that aircraft has fully functioning dual controls. By design, sUAS do not have fully functional dual controls. Flight control is accomplished through the use ofa GCS that communicates with the aircraft viaradio communications .The equivalent level ofsafety is providedby 

### 11

# ~**AIRMI=ID~** Maritime Drone Services I09 Kingston St.


### Phone: +1(201)637-1272 Floor 3, Airmada Inc. c/o Project II Boston, MA 02111 

### www.airmada.com Email: dan@airmada.com the fact thatneither a pilot norpassengers will be carried inthe aircraft, the ability to control the sUAS via radio signals from the controller is unaffected bythe size and speed ofthe aircraft.


### 14 C.F.R. 91.119: Minimum safe altitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. The sUAS will never operate at altitude higher than 400 AGL and all operations will occur during daylight hours underVMC only. The equivalent level ofsafety will be achieved given the size, weight and speed ofthe sUAS as well as the location where it is operated. No flight will betaken withoutthe permission ofthe property owner. Because advance notice to the property owner and any onsite personnel, as well as the precautions outlined below, all affected individuals will be aware ofthe planned flight operations. Flight operations will be conducted at least 500 feet from all non-participatingpersons (persons other than the PIC or SO), vessels, vehicles and structures, unless operations do not present an undue hazard. The sUAS will remain within visual line ofsight ofthe 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 and airport controller ofall operations within 5 miles ofan airport. The FAA will have advance notice ofall operations through the filing ofnotices-to-airmen. Compared to flight operations with aircraft or rotorcraft weighing far more than the sUAS proposed herein, any risk associated with our operations is far less than those presentlypresented with helicopters and other conventional aircraft operating at or below 500 feet AGL. In addition, the low-altitude operations ofthe sUAS will ensure separation between these sUAS operations and the operations ofconventional 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 byreference to an altimeter that is set "
...to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." The sUAS will have a barometric altimeter, in addition to a GPS altitude read out. An equivalent level ofsafety will be achieved bythe PIC confirming the altitude ofthe launch site shown on the GPS altitude indicatorbefore flight and comparing the reading to its barometerreading.

12

# ?**AII=IM'RD~** Maritime Drone Services 1 09 Kingston St.
Phone: +1(201)637-1272 Floor 3, AinnadaInc. c/o Project 11 Boston, MA 02111 www.airmada.com Email: dan@airmada.com 14 C.F.R. 91.151(a): Fuel requirements for flight in VFR conditions Section 91.151(a) outlines fuel requirements for beginning a flight in VFR conditions. Relieffrom Section 91.151(a)(1) is requested to the extent requiredto allow flights ofa variety ofsUAS during daylight hours in VFR conditions to continue until 90 percent ofremaining batterypower or fuel reserves remain. Airmada Inc. seeks the requested reliefbecause without an exemption from Section 91.151(a)(l), the flight time duration ofthe selected aircraft will be reduced and severely constrain the practicality of any aerial acquisition ofdata that Airmada Inc. proposes to conductpursuant to this Petition. The technical specifications ofthe proposed sUAS, their Operations Manuals, andAirmada Inc.'s proposed operatinglimitations, ensurethatAirmada Inc. will safely operate the selected aircraft during daylighthours inVFR conditions until 90 percentofremainingbatterypower orfuel reserves remain.
14 C.F.R. 91.203(a) & (b): Carrying civil aircraft certification and registration The sUAS has no cabin, cockpit orpilot station and is operated without an onboard pilot. Therefore, there is no ability orplace to carry certification andregistration documents orto display them on the sUAS. An equivalent level ofsafety will be achieved bykeeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extentthey are applicable to the sUAS.
14 C.F.R. 91.405; 407 (a)(l); 409 (a)(2); 417 (a) & (b): Maintenance inspections These regulations require that an aircraft operator orowner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall between required inspections, except as provided in paragraph (c) ofthis section, have discrepancies repaired as prescribed inpart43 ofthis chapter
...," and others shall inspect ormaintain the aircraft in compliance with Part 43. Giventhat these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to Airmada Inc. Maintenance will be accomplished pursuant to the user guide or operating manual. An equivalent level of safety will be achievedbecause these sUASs are limited in size and will carry a small payload and operate only in restricted areas for limited periods oftime. Ifmechanical issues arise, the sUAS can land immediately and will be operating from no higher than 400 feet AGL. The PIC will ensure that the sUAS 13

# ~**AIRMiFIO~** Maritime Drone Services 1 09 Kingston St.
Phone: +1(201)637-1272 Floor 3, Airmada Inc. c/o Project 11 Boston, MA 02111 www.airmada.com Email: dan@airmada.com is in working orderpriorto initiating flight, performrequired maintenance and keep a log ofany 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 ofsafety. 

## PUBLIC INTEREST Approval ofexemptions allowing commercial operations ofUASs for aerial acquisition ofdata enhances safety while reducing risk. Manned aircraft in certain application create a greater riskbecause the aircraft are much larger and carry an onboard humanpilot. In contrast, a sUAS weighing 55 pounds orless will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights. In addition, streams ofaerial data will allow large commercial entities to make decisions about how to best deploy ground resources and ensure the safety and cost-effectiveness oftheir operations. 

## EQUIVALENT LEVEL OF SAFETY Airmada Inc. proposes thatthe exemption requested herein apply to civil aircraft that have the characteristics and that operate withinthe limitations listed herein. These limitations provide for at least an equivalent oreven higher level ofsafety to operations under the current and proposed regulatory structure.

14

# ?**AIRMRD~** Maritime Drone Services 1 09 Kingston St.
Phone: +1(201)637-1272 Floor 3, AinnadaInc. c/o Project 11 Boston, MA 02111 www.airmada.com Email: dan@airmada.com


## PRIVACY
All flights will occur overprivate or controlled access property with the property owner's prior consent and knowledge. Images orvideo taken ofindividuals will have consented to being filmed or otherwise they will be made anonymous. 

## NATIONAL SECURITY Given the small size ofthe sUAS involved 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 operations for the activities statedrespecting at all times the space and privacy ofcitizens and property while keeping airspace safe. Sincerely submitted,
Va.e

### V~ 

# (!? DanDanay 109 Kingston St. Floor 3, Airmada Inc, c/o Project 11 Boston, MA 02111 

### +1(201) 637-1272



### 15.......... w

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