? AII=IMRD~ 

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 

September 21, 2015 

From: 

DanDanay 

Ainnada Inc. 

To: 

U.S. Department of Transportation, Docket Operations 

Room Wl2-140 of the west building 

Ground floor 

1200 New Jersey Avenue, SE. 

Washington, DC, 20590 

PETITION FOR EXEMPTION OF: 

Airmada Inc. 

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FOR AN 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 AND FIREFL Y6 

UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA 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 

INTRODUCTION AND INTERESTS OF THE PETITIONER .................................................................. 4 

UNMANED AIRCRAFT SYSTEMS: ALIGN M690L, FIREFL Y6 ........................................................... 5 

BASIS FOR OUR PETITION ...................................................................................................................... 5 

CONDffiONS AND LIMITATIONS .......................................................................................................... 7 

SECTIONS OF 14 C.F.R FROM WHICH AIRMADA INC. SEEKS EXEMPTION ............................... 10 

PUBLIC INTEREST .................................................................................................................................. 14 

EQUN ALENT LEVEL OF SAFETY ....................................................................................................... 14 

PRIVACY ................................................................................................................................................... l5 

NATIONAL SECURITY ........................................................................................................................... 15 

Exhibit A Align M690L SPECIFICATIONS ............................................ . n,'T.:un ill'K il'lrl'Oil !ilK'.:l¥1 

Exhibit B - BIRDSEYEVIEW FireFLY 6 SPECIFICATIONS .................... . n,'T..tln ill'K il"lrl'Oil lilK'.:lW 

2 

Phone: +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 

Maritime 

AIRMRD~ 

~ Drone 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 

Air Traffic Organization 

Code of Federal Regulations 

Certificate of Authorization 

Federal Aviation Administration 

Federal Aviation Regulation 

First Person Video 

Ground Control Station 

Global Positioning System 

Loss of Link 

National Airspace System 

Notice to Airman 

Pilot in Command 

FAA Modernization and Reform Act of2012 (FMRA) Section 333 

Safety Observer 

Small Unmanned Aircraft System 

Visual Flight Rules 

Visual Line of Sight 

Visual Meteorological Conditions 

Vertical Takeoff and Landing 

3 

AIRMRD~ 

~· 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 EmaD: dan@airmada.com 

SUMMARY 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 (The Reform Act), and 14 

C.F.R Part 11, Airmada Inc. a maritime service provider, hereby applies for an exemption from the FARs 

listed below to allow operation ofsUAS commercially in airspace regulated by the FAA so long as such 

operations are conducted with and under the conditions outlined herein or as may be established by the 

FAA as required by Section 333. 

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

services to clients using sUA V in the following areas: 

1. First response 

2. Inspection 

3. Surveillance 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

Airmada Inc. is a maritime service provider. The company inspects vessels and ports from the sky and 

compliments traditional patrol boat uses. By utilizing sUAS, costs and operation hours of traditional 

resources are substantially reduced. The company's objective is to conduct aerial photography and 

videography, in order to provide high quality digital imaging and video content. The content would then 

be used by port authorities, shipping companies, maritime agents, search and rescue missions, etc. 

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

areas: 

• Aerial survey of ports I shipping yards 

• Aerial survey of individual ships I boats 

• Aerial videography to assist port authorities with maritime law enforcement 

• Maritime situational awareness and first response missions, conducted by port authorities. 

4 
. ' 
Phone: +1(201)637-1272 

Maritime 

AIRMRDJ:\ ~ Drone Services 

1 09 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 exemption to operate Align and BIRDSEYEVIEW drones for compensation or 

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

The Align M690L has a maximum gross weight of approximately 15 pounds, 87.5 em in length, 44.6 em 

in length and a maximum speed of 15 meter/second (See Exhibit A). The FireFLY6 has a maximum gross 

weight of approximately 9 pounds, 95 em in length, 152 em of wingspan and a maximum· speed of 26 

meter/second. Both platforms are driven by six lithium polymer battery powered 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 operated by one GCS that 

provides instrumentation data of the aircraft and FPV. Using the GCS, one can set limits on: The altitude 

the sUAV flies AGL. The radius of the 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 Align M690L and FIREFL Y6 have a failsafe function that is triggered in the event 

communication is lost between the sUAS and the main controller transmitter (in the GCS). At that time, 

the sUAS will return to its point of takeoff and land safely. If the communication is restored, the PIC is 

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

when the lithium-polymer battery falls below an operator specified state of charge. In this case the drone 

will also return to its point of takeoff and land safely. The minimum state of charge is set to 60% to allow 

the drone sufficient energy to return from any phase of its mission. 

5 

Phone: +1(201)637-1272 

~· AIRMRO~ 

Maritime Drone Services 

1 09 Kingston St. 

Floor 3, Ainnada Inc. c/o Project 11 

Boston, MA 02111 

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

In addition to the safety features built into the referred sUAS and GCS, Airmada Inc. a company founded 

by former naval officer and SpaceX avionics engineer and launch control operator, has a high bar of 

safety operational standards. Every flight conducted by Airmada Inc. is performed in accordance to a 

written procedure and a checklist. This ensures that all safety features, configurations and equipment has 

been enabled, and all personnel onsite are informed and briefed. 

The fact that the PIC holds an FAA Private Pilot license demonstrates Airmada Inc.'s high regard for safe 

operations with an understanding ofF ARs, preflight inspections, knowledge of operations and differences 

in airspace Classifications, maintenance and repair, as well as being trained to high safety standards. 

Under the requested exemption, Airmada Inc. ensures all operators have completed sUAS education and 

training programs including all applicable regulations and guidance 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 and decision-making and safe operations procedures. 

6 
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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 of these aircraft, Airmada Inc. is committed to the following conditions and limitations on 

its operations. Ainnada Inc. understands that failure to comply will be grounds for the immediate 

suspension or rescission 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 per hour). In no case 

will the aircraft be operated at airspeeds greater than the maximum aircraft operating airspeed 

recommended by the aircraft manufacturer. 

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

reported in feet AGL. 

4. The aircraft will be operated within VLOS of the PIC at all times. This requires the PIC to be 

able to use human vision unaided by any device other than corrective lenses, as specified on the 

PIC's U.S. driver's license. 

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

SO at all times. 

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

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

revised documents if it petitions for extension or amendment. 

7. Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or flight 

characteristics, e.g. replacement of a flight critical component, will undergo a functional test 

flight prior to conducting further operations. This is explicitly codified in Airmada Inc.'s drone 

maintenance manual. 

8. Airmada Inc. is responsible for maintaining and inspecting the 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, MA 02111 

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

9. Prior to 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 operated under this 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, or the Federal government. 

13. Airmada Inc. will not permit 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 of training Airmada Inc. 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 of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an 

ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical 

chart, unless a letter of agreement with that airport's management is obtained or otherwise 

permitted by a COA. 

15. The sUAV will not be opemted less than 500 feet below or less than 2,000 feet horizontally from 

a cloud or when visibility is less than 3 statute miles from the PIC. 

16. If the sUAS loses communications the aircraft will return to a pre-determined location. 

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

18. The PIC will be prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough available power for the aircraft to conduct the intended 

operation and to opemte after that for at least five minutes or with the reserve power 

recommended by the manufacturer if greater. 

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 if the blanket COA 

does not cover the intended operation. 

20. Documents used by Airmada Inc. to ensure the safe operation and flight of the 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 aircraft will remain clear and give way to all manned aviation operations and activities at all 

times. 

22. The sUAS may be operated by the PIC from a moving device or vehicle; however, specific 

requests will be made via subsequent COA. 

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

vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently 

protect nonparticipating persons from the aircraft or debris in the event of an accident; or b. The 

owner/controller/operator of any vessels, vehicles or structures has granted permission for 

operating closer to those objects and the PIC has made an assessment of the risk of operating 

closer to those objects and determined that it does not present an undue hazard. 

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

persons under this exemption. 

25. All operations conducted over private or controlled-access property will be conducted with the 

permission from the property owner/controller or authorized representative. Permission from 

property owner/controller or authorized representative will be obtained for each flight to be 

conducted. 

26. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of 

the operational area as defmed by the applicable COA will be reported to the FAA's sUAS 

Integration Office (AFS -80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

9 

Maritime 

AIRMRD~ 

~ 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 of airworthiness certificates as 

required by FAR §91.203( a)(l ). Given the size and limited operating area associated with the aircraft to 

be utilized by Airmada Inc., an exemption from Part 21 Subpart H meets the requirements of an 

equivalent level of safety under Part 11 and Section 333 ofthe Reform Act. The Federal Aviation Act (49 

USC §4470l(f)) and Section 333 of the Reform Act 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 sUAS. In all cases, an analysis 

of these criteria demonstrates that the sUAS operated without an airworthiness certificate, in the restricted 

environment and under the conditions proposed, will be at least as safe, or safer, than a conventional 

aircraft operating with an airworthiness certificate without the restrictions and conditions proposed. 

14 C.F.R. 45.23(b): Marking of the aircraft 

This regulation requires that certain experimental, provisionally certified aircraft, or light-sport category 

aircraft to be marked with letters between 2 inches and 6 inches high "limited", "restricted," "light-sport," 

"experimental," or "provisional," near each entrance to a cabin, cockpit or pilot station. Even though the 

sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no 

entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed. Given the 

size of the 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) limit private pilots to non-commercial operations. Because the sUAS will not 

carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current 

operations by requiring the pilot operating the aircraft to have completed a sUAS flight-training course. 

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled. The 

area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The 

10 

Maritime 

AIRMRD~ 

~ 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 of the sUAS are so diminished from the level of risk associated with 

commercial operations contemplated by Part 61 when drafted, that allowing operations of the sUAS as 

requested exceeds the present level of safety achieved by 14 CFR 61.113(a) and (b). 

14 C.F.R. 91.7(a): Civil aircraft airworthiness 

The regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. As 

there will be no airworthiness certificate issued for the aircraft Airmada Inc. contemplates operating, 

should this exemption be granted, no FAA regulatory standard will exist for determining airworthiness. 

Given the size of the aircraft and the operational restrictions put on the aircraft, an equivalent level of 

safety will be provided. 

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

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the 

aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such 

an item on the aircraft. The equivalent level of safety will be maintained by keeping the Operating 

Manuals at the ground control point where the pilot flying the sUAS will have immediate access to it. 

14 CFR 91.103: Preflight action 

This regulation requires the PIC take certain actions before each flight to ensure the safety of flight. An 

exemption is needed from this requirement, as the pilot will take separate preflight actions, including 

checking for weather conditions, checking flight battery or fuel requirements, checking takeoff and 

landing distances, and all other actions in the Operating Manual and safety checklists. These actions will 

provide an equivalent level of safety. 

14 C.F.R. 91.109: Flight instruction 

Section 91.103 provides that no person may operate a civil aircraft (except a manned free balloon) that is 

being used for flight instruction unless that aircraft has fully functioning dual controls. By design, sUAS 

do not have fully functional dual controls. Flight control is accomplished through the use of a GCS that 

communicates with the aircraft via radio communications .The equivalent level of safety is provided by 

11 

Maritime 

AIRMI=ID~ 

~ Drone Services 

I 09 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 that neither a pilot nor passengers will be carried in the aircraft, the ability to control the sUAS 

via radio signals from the controller is unaffected by the size and speed of the aircraft. 

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

Section 91.119 establishes safe altitudes for operation of civil aircraft. The sUAS will never operate at 

altitude higher than 400 AGL and all operations will occur during daylight hours under VMC only. 

The equivalent level of safety will be achieved given the size, weight and speed of the sUAS as well as 

the location where it is operated. No flight will be taken without the permission of the property owner. 

Because advance notice to the property owner and any onsite personnel, as well as the precautions 

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

will be conducted at least 500 feet from all non-participating persons (persons other than the PIC or SO), 

vessels, vehicles and structures, unless operations do not present an undue hazard. The sUAS will remain 

within visual line of sight of the PIC or SO. Flight operations will be conducted at least 5 miles from an 

airport. The PIC or SO will provide notification to the local Flight Standards District Office and airport 

controller of all operations within 5 miles of an airport. The FAA will have advance notice of all 

operations through the filing of notices-to-airmen. Compared to flight operations with aircraft or 

rotorcraft weighing far more than the sUAS proposed herein, any risk associated with our operations is far 

less than those presently presented with helicopters and other conventional aircraft operating at or below 

500 feet AGL. In addition, the low-altitude operations of the sUAS will ensure separation between these 

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

14 C.F.R. 91.121: Altimeter Settings 

This regulation requires each person operating the aircraft to maintain cruising altitude by reference to an 

altimeter that is set " ... to the elevation of the departure airport or an appropriate altimeter setting available 

before departure." The sUAS will have a barometric altimeter, in addition to a GPS altitude read out. An 

equivalent level of safety will be achieved by the PIC confirming the altitude of the launch site shown on 

the GPS altitude indicator before flight and comparing the reading to its barometer reading. 

12 

? AII=IM'RD~ 

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 

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. Relief from 

Section 91.151 (a )(1) is requested to the extent required to allow flights of a variety of s U AS during 

daylight hours in VFR conditions to continue until 90 percent of remaining battery power or fuel reserves 

remain. Airmada Inc. seeks the requested relief because without an exemption from Section 91.151(a)(l), 

the flight time duration of the selected aircraft will be reduced and severely constrain the practicality of 

any aerial acquisition of data that Airmada Inc. proposes to conduct pursuant to this Petition. 

The technical specifications of the proposed sUAS, their Operations Manuals, and Airmada Inc.'s 

proposed operating limitations, ensure that Airmada Inc. will safely operate the selected aircraft 

during daylight hours in VFR conditions until 90 percent of remaining battery power or fuel 

reserves remain. 

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

The sUAS has no cabin, cockpit or pilot station and is operated without an onboard pilot. Therefore, there 

is no ability or place to carry certification and registration documents or to display them on the sUAS. An 

equivalent level of safety will be achieved by keeping these documents at the ground control point where 

the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the 

sUAS. 

14 C.F.R. 91.405; 407 (a)(l); 409 (a)(2); 417 (a) & (b): Maintenance inspections 

These regulations require that an aircraft operator or owner "shall have that aircraft inspected as 

prescribed in subpart E of this part and shall between required inspections, except as provided in 

paragraph (c) of this 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 Airmada Inc. 

Maintenance will be accomplished pursuant to the user guide or operating manual. An equivalent level of 

safety will be achieved because these sUASs are 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 sUAS can land 

immediately and will be operating from no higher than 400 feet AGL. The PIC will ensure that the sUAS 

13 

Maritime 

AIRMiFIO~ 

~ 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 order prior to initiating flight, perform required maintenance and keep a log of any 

maintenance performed. Moreover, the PIC is the person most familiar with the aircraft and best suited to 

maintain the aircraft in an airworthy condition to provide the equivalent level of safety. 

PUBLIC INTEREST 

Approval of exemptions allowing commercial operations of UASs for aerial acquisition of data enhances 

safety while reducing risk. Manned aircraft in certain application create a greater risk because the aircraft 

are much larger and carry an onboard human pilot. In contrast, a sUAS weighing 55 pounds or less will 

carry no passengers or crew and, therefore, will not expose them to the risks associated with manned 

aircraft flights. In addition, streams of aerial data will allow large commercial entities to make decisions 

about how to best deploy ground resources and ensure the safety and cost-effectiveness of their 

operations. 

EQUIVALENT LEVEL OF SAFETY 

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

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

an equivalent or even higher level of safety to operations under the current and proposed regulatory 

structure. 

14 

? AIRMRD~ 

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 

PRIVACY 

All flights will occur over private or controlled access property with the property owner's prior consent 

and knowledge. Images or video taken of individuals will have consented to being filmed or otherwise 

they will be made anonymous. 

NATIONAL SECURITY 

Given the small size of the 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 stated respecting at all times the space and 

privacy of citizens 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 

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