Atlanta AirWorX, Inc. , Shawn Rolison 2285 Metropolitan Pkwy Atlanta, GA 30315 Phone: 404

- 427

- 5322

December 1 2 th 2015
United States Department of Transportation Federal Aviation Administration Docket Operations 1200 New Jersey Avenue SE Washington DC 20590

Re: Petition for an exemption seeking relief from specific sections of Title 14 CFR under Section 333 of the FAA Modernization and Reform Act of 2012 (Public Law 112

- 95)

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act o f 2012 and 14 CFR Part 11 Atlanta AirWorX , Inc. hereby seeks an exemption from the Federal Aviation Regulations as detailed below for the purpose of conducting commercial Unmanned Aerial System (UAS) operations in the National Airspace System (NAS).TABLE OF CONTENTS

Page

NAME AND ADDRESS OF THE PETITIONER..................... ..........................................4

BACKGROUND AND OPERATING DESCRIPTION.......................................................4

DESCRIPTION OF UAVs AND GCS...............................................................................5

SECTIONS OF 14 CFR FROM WHICH

Atlanta AirWorX, Inc. , Inc. SEEKS EXEMPTION.

...... ........................................................8

PUBLIC INTEREST............ ............................................................................................12

SAFETY..........................................................................................................................12

SUMMARY SUITABLE FOR THE PUBLIC REGISTER..................................................13

ADDITIONAL INFORMATION, VIEWS, AND ARGUMENTS.....................................13NAME AND ADDRESS OF THE PETITIO NER:

The name and address of the petitioner is:

Atlanta AirWorX, Inc. Shawn Rolison 2285 Metropolitan Pkwy Atlanta, GA 30315 Phone: 404

- 427

- 5322

BACKGROUND AND OPERATING DESCRIPTION

Atlanta AirWor X , Inc. seeks exemption from the requirements of 14 CFR FAR Parts 91.7 (a), 91.9 (b) 2, 91.119, 91.121, 91.151 (a), 91.405 (a), 91.407 (a) 1, 91.409 (a) 1 and 2, 91.417 (a) and (b) pursuant to Section 333 of the FAA Modernization and Reform Act of 2012. This exemp tion will permit Atlanta AirWor X , Inc. to obtain an appropriate Certificate of Authorization to operate the described UAV aircraft below within the NAS for the commercial purpose of collecting aerial photo and video information and data.

Atlanta AirWor X , Inc. was formed in 2015 by S hawn Rolison. Mr. Rolison has been flying and building RC aircraft recreationally for over 20 years and has 5 years of experience operating the type of UAVs that will be flown under the desired exemption. Atlanta AirWor X , Inc. seeks to provide aerial photo and video services for a variety of clients. Examples of services shall include but not be limited to; construction job site progression and mapping, search and rescue, golf course mapping, mining research, residential/commercial real estate b rokers, insurance companies, roofing/construction contractors, filming/cinematic companies.
As set forth in this petition, Atlanta AirWorX , Inc. seeks to commercially operate its UAVs with the highest level of safety and professionalism

.Skyhunter FPV UAV :

The Skyhunter 1.8M UAV is a professional FPV F ixed Wing UAV aircraft. The unit is hand launch and is belly recovery. It is powered by one (1) 3540 Electric Motor and 2 5000

- 10,000mAH battery packs. I t is ready to fly with a gross weight of 6.61 pounds with a flight duration of 30 minutes on a fully charged battery. It has a m aximum speed of 43.44 knots. The Skyhunt e r has the capability to have two operators, one flying the UAV while the other operates the cameras. The flight controller for the Skyhunter is a APM 2.6, which is capable being fully autonomous. It works with Mission Planner Software and offers such modes as GPS Lock, auto landing, auto takeoff, as well as sophisticated mission planning and camera controls. The user can define maximum flight parameters such as altitude a nd/or lateral distance from the GCS.
The Skyhunter uses a separate system to transmit live video feed that displays live video data and flight information to the operator and/or Visual Observer (VO).
Ground Control Station (GCS):
A ground station is typically a software application, running on a ground

- based computer, that communicates with the Skyhunter UAV via wireless telemetry . It displays real

- time data on the UAVs performance and position and serve s as a “vir tual cockpit”, showing many of the same instruments that you would have if you were flying a real plane. A GCS can also be used to control a UAV in flight, uploading new mission commands and setting parameters. It is often also use to monitor the live vide o stream from a UAV’s cameras

.
DJI F550 UAV:

Atlanta AirWorX also plan s on operating a DJI F550 Hex a copter

. Operation is similar to a DJI Phatom and Inspire. The DJI Flamewheel 550 is a pro ven airframe used by many for professional aerial photography. It’s ready to fl y with a gros s weight is 5.3 pounds with a flight duration of 20 minutes on a fully charged battery. It has a maximum speed of 25 k nots.

The DJI F550 has a separate system to transmit live video feed that displays live video data and flight information to the operator and/or Visual Observer (VO).SPECIFIC SECTIONS OF 14 CFR FROM WHICH Atlanta AirWorX, Inc., SEEKS EXEMPTION AND THE

EXTENT OF RELIEF SOUGHT AND THE REASON THAT THE RELIEF IS SOUGHT

The pet itioner believes that as per Section 333 of PL 112

- 95, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, that relief from 14 CFR Part 21 Subpart H regarding Airworthiness Certificate s is not necessary and therefore relief is not sought.
FAR Part 91.7 (a) prescribes that;
No person may operate a civil aircraft unless it is in an airworthy condition.
Relief is requested to maintain an airworthy condition by compliance with the operating procedures and documents prescribed in this petition prior to every flight.
FAR Part 91.9 (b) 2 prescribes that;
(b) No person may operate a U.S.

- registered civil aircraft

— (1) For which an Airplane or Rotorcraft Flight Manual is required by § 21.5 of thi s chapter unless there is available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the manual provided for in § 121.141(b); and
(2) (2) 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, approved manual material, markings, and placards, or any combination thereof.
Relief is requested to comply by keeping all relevant company operating proce dures, limitations, logbooks, and checklists in a location accessible to the PIC.

Far Part 91.119 prescribes in part that;
Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:
(c) Over other than co ngested 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 to any person, vessel, vehicle, or structure.Relief is sought for FAR 91.119 (c) because that UAV aircraft will be operated below 400 feet AGL and

would not be able to comply with this subparagraph. Petitioner would operate in accordance with the limitations described in this petition or by any other limitations the FAA deem s necessary.

Far Part 91.121 prescribes in part that;
(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

— (1) Below 18,00 0 feet MSL, to

— (i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;
(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altim eter setting of an appropriate available station;

or
(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure;

or
(2) At or above 18,000 feet MSL, to 2 9.92′′ Hg.
Relief is sought because the UAV aircraft does not have a typical barometric altimeter on board, and all reported altitudes will be reported in feet AGL.
Far Part 91.151 (a) prescribes that;
(a) No person may begin a flight in an airplane under V FR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

— (1) During the day, to fly after that for at least 30 minutes; or
(2) At night, to fly after that for at least 45 minutes.
(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming norm al cruising speed, to fly after that for at least 20 minutes.Relief is sought to operate at less than the prescribed minimums because UAV will never be flown more

than 1/2 mile from the point of intended landing, and that safety will be maintained by mo nitoring the elapsed time in flight, real time battery voltage condition, and the 2 level low battery warnings detailed above in the UAV description. The PIC will never begin a flight unless there is enough power to fly to the intended point of landing at normal cruising speed and still land with 20% battery power remaining.
Far Part 91.405 (a), 91.407 (a) 1, 91.409 (a) 1 and 2, 91.417 (a) and (b) prescribe that

- 91.405 (a)
Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as pr escribed 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;
91.407 (a) 1
(a) No person may operate any aircraft that h as undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for return to service by a person authorized under §43.7 of this chapter; and
91.409 (a) 1 and 2
(a) Except as provided in paragraph (c) of this se ction, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

— (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or
(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.
91.417 (a) and (b)
(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following 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 appro priate, 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 dat e of completion 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:
(i) The total time in service of the airframe, each engine, each propeller, 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 spe cified time 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 airworth iness 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 ) Copies 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 prescri bed:
(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 re tained and transferred with the aircraft at the time the aircraft is sold.
(3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for retu rn to service.
Relief from these sections is sought because it is our intention to perform any maintenance and inspections as described in the operations manual of either UAV above and that this will ensure a high level of safety. The PIC will be responsib le for ensuring that the aircraft is in airworthy condition prior to every flight. The PIC will document any work performed in the aircraft logbook as well as cumulative flight time.
SIMILAR EXEMPTIONS They are similar in all/or many material respects to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213PUBLIC INTEREST

The use of sUASs can significantly promote safe and eff ective Construction Jobsite inspection and tracking. The use of sUASs can reduce the risk to workers while inspecting, surveying, or monitoring installation of work that requires ladders, scaffolds or other potentially hazardous means of elevated access. s UASs can inspect, photograph, video and collect data on inaccessible areas that otherwise would require worker inspection, in addition to providing facility security and emergency response reconnaissance. sUASs can also provide high resolution aerial image ry, elevation measurement, mapping, and thermal imagery data.
Reducing manned flight and human inspection of such sites through sUAS use for site imaging will reduce risk to workers and ground personnel and create an improved safety operating environment. Manned aircraft are at risk of fuel spillage and fire in the event of an incident or accident. The sUASs that will be used carry no fuel, and therefore the risk of fire following an incident or accident due to fuel spillage is eliminated.

THE REASONS WHY GRANTING THE REQUEST WOULD NOT ADVERSELY AFFECT SAFETY

Because of the speed, weight, size, and limited operating area associated with the proposed UAV aircraft operations, the Petitioner submits that our proposed flights would not create a hazard to other users of the NAS or to the public or otherwise pose a t hreat to national security.

I also submit that Atlanta AirWorX , Inc. can safely operate in the NAS pursuant to FMRA Section 333 because:

➢ The PIC is qualified and has an abundance of operational experience.

➢ Flights will be operated within line of sigh t of a pilot and/or observer.

➢ Flights will be terminated at 20% battery power reserve.

➢ Flights will be operated at an altitude of no more than 400ft AGL

➢ Flights will only be operated in reasonably safe environments that are strictly controlled, ar e away from airports and actively populated areas.

➢ A briefing will be conducted for planned UAS operations prior to each flight.

➢ Consent will be obtained from all persons involved in the operation.

➢ If the UAS loses communications, the UAS will be placed in "Return to Home" mode and will return to its point of takeoff.

➢ The UAS flight will be aborted should circumstances arise that would create a potential hazard to person or property.

➢ Atlanta AirWorX, Inc. will operate to ensure the highest level of safety to ourselves, our clients, and the public.SUMMARY SUITABLE FOR THE PUBLIC REGISTER

Atlanta AirWorX, Inc. seeks exemption from the requirements of 14 CFR Parts 91.7 (a), 91.9 (b) 2, 91.119, 91.121, 91.1 51 (a), 91.405 (a), 91.407 (a) 1, 91.409 (a) 1 and 2, 91.417 (a) and (b). This exemption will permit Atlanta AirWorx, Inc. to commercially operate a UAV aircraft for the purpose of collecting aerial photo and video assets for a variety a clients.

ADDITIONAL INFORMATION, VIEWS, AND ARGUMENTS

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 Section 333. As stated above, Atlanta AirWorX, Inc. , Will operate safely in the NAS without creating an undue hazard to other users of the NAS, the general public, or by posing a threat to national security. Atlanta AirWor X, Inc. , operation will also provide a benefit to the public interest as detailed in this petition.

In Conclusion: Atlanta AirWor X , Inc. , the Petiti oner request for exemption from the above mentioned Federal Aviation Regulations in order to legally operate an Unmanned Aircraft System (UAS) in the National Airspace System in order to perform the Applications and Operations pertaining to my business in a safe and controlled environment. The Petitioner hopes for a timely consideration as I have made a considerable investment in time and finances on this project.

S incerely ,

Atlanta AirWorx, Inc. Shawn Rolison , President 2285 Metropolitan Pkwy Atlanta, Georgia 30315 404

- 427

- 5322 search49@live.com