# C **rescent** 

## A **erial** 

### I **maging LLC**

2245 Beck St. New Orleans, La 70131 Phone: 504 - 577 - 1147 E - Mail: crescentaerialimaging@gmail.com 9 July , 2015 U.S. Department of Transportation, Docket Operations Federal Aviation Administration West Building Ground floor, Room W12 - 140 1200 New Jersey , Avenue, SE, Washington DC 20590 Subject: Petition for exemption of applicable requirements of title 14, Code of Federal Regulat ions (14 CFR) for CrescentA I’s S mall Unmanned Aircraft S ys tem (sUAS) To whom it may

concern, Crescent Aerial Imaging LLC wishes to petition from specific regulations of Title 14 of the Code of Federal Regulations. These exemptions are pursuant to Section 333 of the FAA Modernization and Reform Act of 2012. PL 112 - 95, February 14, 2012, 126 Stat 11. Crescent Aerial Imaging (CrescentAI) aims to utilize Small Unmanned Aerial Sy stems (sUAS) to capture high qualit y video and still imagery for several industries. Our target market is Real Estate and land/Construction sites, motion picture and entertainment industry, and the oil & gas and electrical utilities industry . Providing the Real - Estate industry with high quality

aerial still images will greatl y increase value brought to their customers. Our high quality aerial video adds value through virtual propert y tours and will give our customers a competitive edge. This request is in - line with previously approved exemptions (e.g. Exemption No. 11138). With Holly wood south based in New Orleans, CrescentAI will serve the motion picture and entertainment industry , bringing the same high quality of service. CrescentAIwill also provide service to the oil & gas industry with a safer less costly method for Flare Tip Inspection/Assessm ents and will provide services for other aerial assets. Our use of unmanned aerial photograph y and video drastically reduces costs and risks associated with traditional aerial inspection practices currently in use.Our inspection methods using small unmanned aircrafts reduces operator expenses by orders of magnitude and eliminates nearl y all personnel safety risks. We seek to provide aerial inspection services to the electrical utility industry for structural inspection/assessment (e.g. Tower and Electrical line damage). As in other industries, CrescentAI can mitigate costs and risks by using our (sUAS). The skills, experience, and technologies we've harnessed at CrescentAI enable us to provide a valuable service while maintaining the highest concern for safety and privacy . We hope (expect) the FAA will see the value in our services and recognize the importance we place on safety and privacy as addressed below. With the permission of the FAA, CrescentAI plans to operate commerciall y at or below 400’ AG L as outlined in the FAA Modernization and Reform Act of 2012, section 333 for all possible scenarios pursuant to the above listed industries. CrescentAI understands that any mission outside of those industries listed above will require additional exempti ons or modifications to this exemption. We also understand that this applies to the altitude requirements. CrescentAI will operate small unmanned aircraft (sUAS) weighing less than 50 pounds with full payload. Our aircraft have high visibility markings and characteristics should there be an unfortunate encroachment of our operating area b y any general aviation manned aircraft. Our operating procedures require that all our flight operations cease immediately upon visual recognition of manned aircraft near or heading for our operational area. Our procedures allow that operations may

onl y resume when the area is deemed entirely free from present or approaching manned aircrafts. All flight operations will be conducted in Visual L ine - of - Sight (VLOS) and will no t cause a hazard to life or property . CrescentAI flights will not cause any hazard to the NAS or pose a threat to national security . Visual Meteorological Conditions (VMC) for weather minimums will be adhered to as prescribed in §91.155. CrescentAI will strictly compl y with the minimum safe altitudes regulated under §91.119. All sUAS aircraft flown by CrescentAI will be operated at airspeeds less than 40 knots, for this is the maximum operating airspeed to acquire quality video and data collection for our c lients. The vast majority of our missions require slow deliberate movements. All of CrescentAI’s aircraft have built - in programmable failsafe s ystems in the event we have a loss of signal or communications between the transmitter and the receiver. This fai lsafe s ys tem allows for an automatic override of the autopilot sy stem and forces a safe vertical landing at the coordinates automatically recorded at takeoff.. All CrescentAI flight crews will be equipped with several tools to ensure safe flight operations to include: ● FAA NOTAM site https://pilotweb.nas.faa.gov/PilotWeb/ ● Sky Vector for Airport locations and maps http://sky vector.com/ ● A variet y of weather si tes and apps for weather checks and clearances (e.g. http://www.accuweather.com/ , http://www.intellicast.com etc).As part of the pre - flight procedures, flight crews will be required to determine Go/ No - Go for

flight operations according to weather, location, obstacles. CrescentAI currently

possess only

one sUAS for commercial operation however would like to expand in the future and operate several more flight crews and aircraft. Any future aircraft operated b y CrescentAI will have the same characteristics as our current one. A description and specifications are enclosed. CrescentAI currently

operates the Tarot T810 Hexacopter. The hexacopter affords an additional degree of safet y as the “Quad - Copter” does not. The hexacopter can be landed safel y in the event of a motor failure. The autopilot can compensate for the loss and allow the pilot/operator to land it in a safe area preventing damage t o propert y and injuries on the ground. The specifications are as follows: **Specifications :**

- Fram e weight : 1020g

- Arms diameter : 25mm

- Aircraft diameter : 810mm

- End to end : 850mm

- Center body dimension : 210 x 210 x 2.0mm

- Mount mounting hole : 1 6mm / 19mm / 25mm / 27mm triangular shaped mounting

- Aircraft weight (everything it needs to fly) : around 4.3kg

- Aircraft all - up - weight (when it lift the ground with payload) : around 4.5~6kg

- Payload (it can carry) : 1.5~2kg **Our Flight Reference :**

- Battery Supply : 2 x 6S 22.2V, 5000mah for 15 - 17 Minutes flight time

- Motor : Tarot 4114 320kv Motor

- ESC : Hobbywing Platinum 30A - OPTO

- Propellers : Tarot 1355 Carbon Fiber Propellers with 1245’s as a Backup

- Flight Autopilot Controller : NAZA - M V2 M ultirotor Autopilot w/GPS and Telemetry capable

- Radio Set : 2.4 GHz Futaba T8J **Payload:**

- Carrying: 2 Axis BGC 3.1 Alex MOS Brushless Motor Gimbal

- TS352 FPV System (Not Goggles, monitors only)

- GoPro Hero 3 This Tarot T810 in its current configur ation will be flown in GPS mode and/or attitude mode. We plan to launch missions using full y autonomous flight as the need arises and the resources become available. We seek approval for use of autonomous guidance s ys tems for future use . We would also like to upgrade our camera and gimbal sy stem in the future to accommodate a DSLR camera and 3 axis gimbal.We request that the FAA permits this for future equipment upgrade in this exemption in order to

simplify these anticipated equipment upgrades which do n ot alter the nature of the aircraft.

**Request for Exemption From:**

● **§ 21.1 Subpart H** Airworthiness Certificates Exemption Justification Based on the size, weight and operational area of CrescentAI’s (sUAS)’s exemption from part 21 is permitted due to CrescentAI meeting an equivalent level of safety pursuant to Section 333 of the reform act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both (49 U.S.C. **§** 44701) (f) and Section 333 of the reform act. Both pieces of legislation permit the FAA to exempt sUAS’s from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability, and proximity of areas such as airports and dense populations. CrescentAI will meet or exceed these elements. ● **§ 45.23 (a) (b)** Display of marks; general Exemption Justification Given the ty

pe and size of CrescentAI’s sUAS aircraft, it is not possible to follow § 45.23 (a) (b) requirements fo r display of marks . If in the future the FAA requires “N” numbers for sUAS’s we ask for an exemption from mounting marking on the aircraft and that we be allowed to include that information with the ground flight crew documentation which would allow for av ailability

for inspection upon request. ● **§ 61.113 (a)** : Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carryi ng passengers or property fo r compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. Exemption Justification CrescentAI will not pilot any aircraft carrying passengers or cargo/propert y; however it requests approval to operate i n a commercial capacity for compensation or hire its sUAS aircraft for collecting aerial photographs and video for all industries outlined above until such time as the administration establishes a standard for national regulation for unmanned aircraft oper ations pursuant to Public L aw 112 - 95. ● **§ 91.119** Minimum safe altitudesExemption Justification

14 CFR § 91.119 allows for helicopters to operate at lower altitudes in certain conditions. Mentioned previously

in this request, CrescentAI has no intentions of flying above 400’ AGL. This will allow for a level of safety equivalent to the minimum safe altitudes prescribed b y 14 CFR § 91.119. As a standard practice and part of CrescentAI’s SOP (Standing Operating Procedure), we will operate in cordon ed off areas, clearl y marked and Restricted to CrescentAI personnel. Given the size, weight, maneuverability, and speed of CrescentAI’s (sUAS)’s, an equivalent level of safet y will be achieved. ● **§ 91.203** (a) (2) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second cop y of the Aircraft registration Application as provided for in § 47 .31(c), or a registration certification issued under the laws of a foreign country . Exemption Justification CrescentAI requests an exemption from producing a registration for its (sUAS). This request goes hand - in - hand with the above request for exemption from § 21.1 Subpart H. This request acknowledges Order 8130.20 regarding registration requirements for United States civil aircraft seeking airworthiness and requests relief until such time as the administration establishes a standard for national regulation for unmanned aircraft operations pursuant to Public Law 112 - 95. ● **§ 91.203 (b)** Civil aircraft: Certifications required - No person may operate a civil aircraft unless the airworthiness certificate required b y paragraph (a) of this section or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. Exemption Justification Due to the fact that CrescentAI’s aircraft are unmanned, we ask that it be approved to allow airworthiness documentation or FAA approved equivalent accessible to the ground based flight crew at all times. T his documentation will be part of the aircraft flight log book and other documentation required by company policy .  **§ 91.407** Operation after maintenance, preventive maintenance, rebuilding, or alteration. Exemption Justification I n consideration of the weight, size, speed, ty pe, maneuverability

and pursuant to § 21.1 Subpart H, CrescentAI is requesting an exemption from § 91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration. The sUAS that CrescentAI operates is nothing more than a hobb yi st aircraft and does not have the same maintenance and repair requirements as the ty pical civil aircraft. CrescentAI’s owner/operator is also A&P Certified and will oversee an y maintenance and repairs completed b y employees of CrescentAI.● **§ 91.9** Civil aircraft flight manual, marking, and placard requirements. For which an

Airplane or Rotorcraft Flight Manual is not required by § 21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, appr oved manual material, markings, and placards, or an y combination thereof. Exemption Justification Due to the fact that CrescentAI’s aircraft are unmanned and it is not possible to stow manuals on - board the aircraft, we ask that it be approved to allow for the aircraft manual, if applicable, to be present with the ground flight crew in lieu of aircraft manual available in the aircraft. The FAA has previously issued exemptions to this regulation in exemptions 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 1016 7, 10167A, 10602, 10700 and 32827.

Crescent Aerial Imaging LLC has strict operating procedures for the safet y of personnel and equipment on the ground. Display ed below are items used by ground personnel while operating our (sUAS)’s. **Ground Equipment** ● Sa fety Helmet (When Applicable) ● High Visibility Clothing ( Hi - Vis as needed) ● Orange Cones for cording off work area (When Applicable) ● Cell Phone, Tablet, Laptop etc. for planning, weather checks, and emergencies Our Pre - Flight Checklist (Continuously upd ated as needed)**Additional Information**

The Applicant, Keith J Stoltz is the owner and sole operator of Crescent Aerial Imag ing LLC (CrescentAI). He is a twenty eight year veteran of the Army and Louis iana Army National Guard with twenty five of those years as Military Aviation Experience which includes operating as a member of the flight crew for multiple Rotor Wing Aircraft including the UH60 Blackhawk, OH58 A/C, and the UH - 1 Huey. He holds a Federal Aviation Administration Airframe & Power plant Certification and has completed the Eurocopter factory course for the BK117/UH72 Lakota. He also has completed the OSHA 40 hour Compliance Course and is a TWIC card holder. Itis the hopes of CrescentAI that the FAA will see the value their service brings to the market place and will approve all exemption requests . By satisfying the criteria provided in Section 333 of the Reform act of 2012, we believe it will be adequate justification for granting of all exemptions thereby allowing for the commerci a l operation of the applicants sUAS. On behalf of Crescent Aerial Imaging LLC, I thank you for your consideration of this petition for exemption and look forward to your comments and suggestions so that we may continue to work towards a common objective.