August 1Oth, 20 15 

Unmanned Aircraft Systems Integration Office 

Federal Aviation Administration 

800 Independence A venue, S W 

Washington, DC 20591 

U.S. Department of Transportation, Docket Operation 

West Building Ground Floor, Room w12-140 

1200 New Jersey A venue, SE 

Washington, DC 20590 

To whom it may concern, 

Derrick Reid Stacy 

EagleEye Imagery, LLC. 

2945 Peaks Mill Drive 

Lexington, KY 40511 

(859) 494-5694 

derrickstacy@gmail.com 

EagleEye Imagery, LLC (E.E.) respectfully requests an exemption from several 

provisions ofTitle 14 of the Code ofFederal Regulations (C.F.R.) to permit the use of 

small unmanned aerial systems (sUAS) to provide aerial photography an~ video, as well 

as to assist in the evaluation of infrastructure and operations for our clients. This request 

is motivated primarily by the desire to maximize safety in infrastructure and operations. 

An exemption would allow A.l. to broadly evaluate assets and operations with sUAS, 

resulting in a safer and more efficient infrastructure network. Accordingly, the grant of 

an exemption is consistent with Congress' intent, reflected 'in Section 333 of the FAA 

Modernization and Reform Act of2012 (Modernization Act),1 that safe systems be 

permitted in the national airspace prior to the issuance of final regulations governing 

general use of these systems.2 A summary of thjs request suitable for publication in the 

Federal Register is provided as Appendix A. 

Appendix B provides the manufacturers information regarding the design, aircraft 

performance, and fail-safe features. We have provided manufacturer information related to 

operating limitations, normal and emergency procedures, and maintenance and inspection 

procedures. As we add aircraft designs, we will update this appendix appropriately. 

Appendix C provides the EagleEye Imagery, LLC Operations Manual for flights covered 

under this Exemption Request. 

1 P.L. 112-95, 126 Stat II. February 14, 20 12. ' 2 Section 333(b) (2) specifically contemplates that the FAA may issue a certificate o f waiver upon a findin g that a type 

of UAS, as a result o f its size, weight, speed, ope rationa l capacity, proximity to airports and populated areas. and 

operations within visual line of sight do not create a hazard to users of the NAS or the public or pose a threat to national 

security. 
motor vehicles, on foot, in specialized equipment. This is often a labor-intensive and 

sometimes arduous job. While our clients do all they can to make these inspections as 

safe as possible, there is an irreducible element of risk involved whenever employees are 

required to go out on structures. Employees may need to climb over or onto structures, 

which can be slippery, rough, and/or exposed to the elements. Some structures, such as 

bridges, are high above the ground. Equipment moving through inspection zones can 

increase risk as well, especially in high-traffic areas. While the use of sUAS for 

supplemental infrastructure and general asset evaluation would not eliminate 

these risks entirely (as it is an additive safety measure), it would reduce the risks to 

employees by allowing for remote aerial review. 

Additionally, the sheer amount of assets and the widely dispersed locations - in many 

instances far from sizeable population centers - means that visual inspection in all 

instances by company personnel can be inefficient. Aerial analysis by traditional fixed 

wing aircraft is impractical because the required altitudes for safe fl ight reduce visibility 

below meaningful levels- it is sitr.ply not possible to see all asset anomalies from such 

heights. Helicopters present better vantage points; however manned helicopters are much 

more costly, subject to human safety and carry highly explosive jet fuel making them 

impractical for deployment. By using sUAS for supplemental asset evaluation, EagleEye 

Imagery, LLC will be able to substantially upgrade its capacity to detect and address 

issues with the right-of-way and other assets before they become a problem for safe 

operations. Thus, the use of sUAS has the potential to improve efficiency, resulting in 

faster and safer delivery of goods, energy & natural resources vital to the U.S. economy. 
Granting an Exemption will not Adversely Affect Safety 

EagleEye Imagery, LLC notes that there is no applicable standard for an equivalency 

determination. Some have argued that the appropriate standard is that for model aircraft, 

noting that their operations, if conducted for recreational purposes, would fall completely 

within the allowable operations for model aircraft. We believe it is difficult to argue that 

there is sufficient correlation between model operations controlled by the Academy of 

Model Aeronautics and the ones contemplated by EagleEye Imagery, LLC. At the same 

time, it is clear that equivalency cannot be established for traditional, manned civil aircraft 

because the design and use profiles between traditional aircraft and sUAS are simply too 

different. As such, we believe it makes more sense to focus on why the contemplated 

operations would not adversely affect safety, which is all that §11.81(e) requires. 

Granting an exemption will not adversely affect safety. EagleEye Imagery, LLC 

contemplates conducting sUAS operations over client owned or controlled land, solely 

during daylight hours, at altitudes well below 200' . ln general, sUAS operations are 

intended to be conducted in areas distant from both congested areas and airports. 

Moreover, because of the inherent risks presented by standard infrastructure operations, 

our clients have already taken steps to secure property against unauthorized public 

access. For example, substantial stretches of pipeline, utilities, and oil and gas 

production sites are fenced, elevated, or otherwise secured to prevent access. Other long 

stretches of infrastmcture are, as noted above, in very remote wilderness areas. The 

nature of operations anticipated by EagleEye Imagery, LLC requires that the sUAS be 

flown at relatively low altitudes and relatively low speeds. EagleEye Imagery, LLC 

expects that in most instances, the sUAS will be flown less than 100 feet from the 

highest structure along the path of the sUAS. Accordingly, the risk of interference with 

another aircraft is minimal. EagleEye Imagery, LLC also plans to conduct sUAS 

operations at least three miles from any public airports (including heliports). In the event 

an operation needs to be conducted closer to an airport, EagleEye Imagery, LLC will 

inform the airport operator and airport air traffic conh·ol tower of the contemplated 

operation and will comply with any directions issued by air traffic control at that airport. 

Approval of exemptions allowing commercial operations of sUASs in the infrastructure 

aerial inspection industry will enhance safety by reducing risk. Conventional operations, 

using jet or piston power aircraft, operate at extremely low altitudes just feet from the 

subject being inspected and in extreme proximity to people and stmctures; and present 

the risks associated with vehicles that weigh in the neighborhood of 4,0001bs., carrying 

large amounts of jet A or other fuel ( 140 gallons for jet helicopters). Such aircraft must 

fly to and from the inspection site. In contrast, a sUAS weighing fewer than 55 lbs. and 

powered by batteries eliminates virtually all of that risk given the reduced mass and lack 

of combustible fuel can·ied on board. The sUAS is carried to the inspection site. The 

sUAS will carry no passengers or crew and, therefore, will not expose them to the risks 

associated with manned aircraft flights. 

The operation of small UASs, weighing less than 55 lbs., conducted in the strict 

conditions outlined above, will provide an equivalent level of safety supporting the grant 

of the exemptions requested herein, including 333 Aircraft Exemption Status exempting 

the applicant from conventional aircraft requirements and allowing commercial 
operating area. Should there be a mishap, the sUAS being flown pose significantly less of 

a threat than the helicopters and fixed wing aircraft now being employed because they are 

a fraction of the size, carry no flammable fuel, do not carry crew or passengers, and pose 

an infinitesimal risk to others. This is in stark contrast to conventional aircraft that are 

flown to the site, carry explosive fuel, carry passengers and crew, and operate in a much 

larger area. 

From a practical standpoint, there are relatively few licensed full-scale aircraft pilots who 

are also qualified to fly the type of sUAS that are utilized for infrastructure image-capture 

operations. There are even fewer commercial pilots that can fly these sUAS- to the point 

that to do both is considered rare. Assuming that it is unlikely for a company to find a 

pilot that has both qualifications, that company would either have to source a qualified 

sUAS pilot to train and obtain a commercial certificate, or find a commercial certificated 

pilot who would be willing to learn to fly a sUAS to the competency level required for 

professional use. 

Minimum requirements for the PIC include: 

1) A minimum of200 flight cycles and 25 hours oftotal time as a sUAS rotorcraft 

pilot; 

2) A minimum of 5 hours as sUAS pilot with the make and model of sUAS to be 

utilized for operations under the exemption and 3 take offs and landings in the 

preceding 90 days; 

3) Have undergone a qualification process as specified in the Flight Operations & 

Procedures Manual consisting of a knowledge & skill test of the aircraft to be 

used. 

Another consideration supp011ing the certificate requirement is that pilots are subject to 

security screening by the Depruiment of Homeland Security. This requirement should 

ameliorate security concerns over UAS operations under this exemption. 

EagleEye Imagery, LLC intends to use commercially available sUAS Components for 

sUAS. These sUAS systems will be tested for quality & safety in our test faci lity before 

being deployed to the field. The sUAS is less than 55 lbs. fully loaded, cru-ries neither a 

pilot nor passenger, and operates exclusively within a secured ru·ea. We have a routine 

maintenance schedule to verify that the sUAS will remain in safe and operational 

condition. Please see Appendix B, for Specific Types of sUAS. 

Notes Regarding: 14 C.F.R. Pru121. Subpart H 

In accordance with the statutory criteria provided in Section 333 of PL 112-95 in 

reference to 49 USC 44 704, and in consideration of the size, weight, speed, and limited 

operating area associated with the aircraft and its operation, we request that this 

aircraft exemption meets the conditions of Section 333. Therefore, if granted Section 

333 relief of 14 CFR part 21, and any associated noise certification and testing 

requirements of part 36, is not necessary. 
EagleEye Imagery, LLC Safety Operations & Procedures Overview: 

Technology Considerations: 

Best-in-class, tried and proven technologies that are in advanced iterations. Software from 

highly-reputable industry partners will include features -

I. Auto descent (landing) if communication signal were to be severed. If the sUAS 

loses commun ications, the sUAS will have capability to return to a pre-determined 

location within the Security Perimeter and land. 

2. Auto descent (landing) if battery were to drop lower than nominal level. 

3. Flights w ill be terminated at 25% battery power reserve. 

4. Live video for operator gives real-time positioning feedback. In other words, we 

can monitor the scene from the veh icle's perspective for collision avoidance, and to 

maintain spatial orientation. 

5. The sUAS will have the capability to abort a flight in case ofunpredicted obstacles 

or emergencies. 

6. On-Screen-Display (OSD) contains operating information to ascertain veh icle 

health at a ll times: speed, altitude, number ofGPS satellites (when ava ilable), 

heading and vo ltage. 

7. GPS lock supplies for return-to-home (RTH). Should Command and Control (C2) 

link fa il ures occur (highly improbable), vehicle returns automatically to the point of 

launch. 

8. A ltitude information will be provided to the sUAS pilot via a digitally encoded 

telemetric data feed, which downlinks from the a ircraft to a ground-based on-screen 

display. This altitude information will be generated by equipment installed on board 

the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or 

radio a ltimeter, or any combination thereof. Prior to each flight, a zero a ltitude 

initiation point w ill be established and confirmed for accuracy by the pi lot. 

Mechanical/Physical: 

I. EagleEye Imagery, LLC will fly line-of-sight (LOS) only. The veh icle will a lways 

remain in d irect LOS to the pilot, thus eliminating the concern of signal severance 

(flying behind objects/walls). 

2. The sUAS w ill weigh less than 55 lbs and travel at less than 50 knots. 

3. Batteries should far exceed the capacity required for actual flight time. 

4. Flights will be operated at an altitude of no more than 400 feet AGL. 

5. Fireproof bags for storage and charg ing of high capacity Lipo batteries on-site. 

6. UA operated under this exemption will be marked in accordance with 14 CFR 

part 45 or as otherwise authorized by the FAA. 

Personnel: 

I. Spotters ensure safe operc.tion and act as a redundant set of eyes for operators 

(pilot, gimba l op, director) 

2. Radio spectrum analysis for interference on the frequencies utilized for vehicle 

control/commun ication. 

3. A briefing will be conducted in regard to the planned sUAS operations priorto 

each day's activities. It will be mandatory that a ll personnel who will be perform ing 

duties within the boundaries of the safety perimeter be present for th is briefing. 

4. The operator will obtain the consent of all persons involved in the sUAS operations 
and ensure that only consenting persons will be al lowed with in I 00 feet of the flight 

operations. 

5. Observer and pilot will at all times be able to commun icate by voice. 

6. Written and/or oral permission from the relevant property holders will be obtained. 

7. Pilot and observer will have been trained in operation of UAS generally and 

received up-to-date information on the particular UAS to be operated. 

Operations: 

I. The unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg), 

including energy source(s) and equipment. Operations authorized by this petition 

of exemption are limited to the fo llowing aircraft described in Appendix B. 

Proposed operations of any other aircraft will require a new petition or a petition 

amendment to this request. 

2. The UA may not be flown at a ground speed exceeding 50 knots. 

3. Flights must be operated at an altitude of no more than 400 feet above ground 

level (AGL), as indicated by the procedures specified in the operator's manual. 

All altitudes reported to ATC must be in feet AGL. 

4. The UA must be operated within visual line of sight (YLOS) 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 FAA-issued medical 

certificate. 

5. All operations must utilize a visual observer (YO). The YO may be used to 

satisfy the YLOS requirement as long as the PIC always maintains YLOS 

capability. The YO and PIC must be able to comn1lmicate verbally at all times. 

6. The operator's manual included as Appendix C and this petition of exemption 

must be maintained and made available to the Administrator upon request. If a 

discrepancy exists between the conditions and limitations in this exemption and 

the procedures outlined in the operator's manual, the conditions and limitations 

herein take precedence and must be followed. Otherwise, the operator must 

follow the procedures as outlined in its operator's manual. 

The operator may update or revise its operator's manual. It is the operator's 

responsibility to track such revisions and present updated and revised documents 

to the Administrator upon request. The operator must also present updated and 

revised documents if it petitions for extension or amendment. If the operator 

detennines that any update or revision would affect the basis for which the FAA 

grants this petition for exemption, then the operator must petition for amendment 

to their exemption. The FAA's UAS Integration Office (AFS-80) may be 

contacted if questions arise regarding updates or revisions to the operator's 

manual. 

7. Prior to each flight the PIC must inspect the UAS to ensure it is in a condition 
for safe flight. If the inspection reveals a condition that affects the safe operation 

of the UAS, the aircraft is prohibited from operating until the necessary 

maintenance has been performed and the UAS is found to be in a condition for 

safe flight. The Ground Control Station, if utilized, must be included in the 

preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS 

operation or flight characteristics, e.g. replacement of a flight critical component, 

must undergo a functional test flight in accordance with the operator's manual. 

The PIC who conducts the functional test flight must make an entry in the UAS 

aircraft records of the flight. The requirements and procedures for a functional test 

flight and aircraft record entry must be added to the operator's manual. 

9. The operator must follow the manufacturer's UAS aircraft/component, 

maintenance, overhaul, replacement, inspection, and life limit requirements. 

When unavailable, aircraft maintenance/component/overhaul, replacement, and 

inspection/maintenance requirements must be established and identified in the 

operator's manual. At a minimum, requirements for the following must be 

included in the operator's manual: 

a. Actuators I Servos; 

b. Transmission (single rotor); 

c. Powerplant (motors); 

d. Propellers; 

e. Electronic speed controller; 

f. Batteries; 

g. Mechanical dynamic components (single rotor); 

h. Remote command and control; 

i. Ground control station (if used); and 

j . Any other components as determined by the operator; 

I 0. The PIC must meet the flight review requirements specified in 14 CFR § 

61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

I 1. Prior to operations conducted for the purpose of infrastructure inspections, the 

PIC must have accumulated and logged, in a manner consistent with 14 CFR § 

61.51(b), a minimum of200 flight cycles and 25 hours of total time as a UAS 

rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS 

type (single blade or multirotor). Prior documented flight experience that was 

obtained in compliance with applicable regulations may satisfy this requirement. 

Training, proficiency, and experience-building flights can also be conducted 

under this petition of exemption to accomplish the required flight cycles and flight 

time. During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered nonparticipants, and the PIC must 
operate the UA with appropriate distance from nonparticipants in accordance ·with 

14 CFR § 9 1. 119. 

12. Prior to operations conducted for the purpose of infrastructure inspection, the 

PIC must have accumulated and logged, in a manner consistent with 14 CFR § 

61.51(b), a minimum offive hours as UAS pilot operating the make and model of 

UAS to be utilized for operations under the exemption and three take-offs and 

three landings in the preceding 90 days. Training, proficiency, experiencebuilding, and take-off and landing cunency flights can be conducted under this 

petition of exemption to accomplish the required flight time and 90 day currency. 

During training, proficiency, experience-building, and take-off and landing 

cunency flights all persons not essential for flight operations are considered 

nonparticipants, and the PIC must operate the UA with appropriate distance from 

nonparticipants in accordance with 14 CFR § 9 1.1 19. 

13. Prior to any flight operations authorized by this petition of exemption, the PIC 

and YO must have successfully completed a qualification process, as outlined in 

the operator's manual. As this is a requirement stipulated by the operator, the test 

must be developed and implemented by a qualified person designated at the sole 

discretion of the operator. A record of completion of this qualification process 

must be documented and made available to the Administrator upon request. 

14. Prior to operations conducted for the purpose of infrastructure inspection, a fl ight 

demonstration, administerea by an operator-approved and -qualified pilot must be 

successfully completed and documented. This documentation must be availablefor 

review upon request by the Administrator. Because the knowledge and airmanship 

test qualifications have been developed by the operator, and there are no established 

practica l test standards that support a jurisdictional FAA rSDO evaluation and 

approval of company designated exam iners, the petitioner will conduct these tests in 

accordance with the operator's manual. 

15. The UA may not be operated directly over any person, except authorized and 

consenting personnel, below an altitude that is hazardous to persons or property on 

the surface in the event of a UAS fai lure or emergency. 

16. Regarding the distance from participating persons, the operator's manual has 

safety mitigations for authorized and consenting personnel. At all times, those 

persons must be essential to the operations. 

17. Regarding distance from nonparticipating persons, the operator must ensure that 

no persons are allowed within 500 feet of the area except those consenting to be 

in volved and necessary for the infrastructure inspection operations. This provision 

may be reduced to no less than 200 feet if it would not adversely affect safety and the 

Administrator has approved it. For example, an equivalent leve l of safety maybe 

determ ined by an aviation safety inspector's evaluation of the infrastructure 

inspection area to note terrain features, obstructions, buildings, safety barriers, etc. 

Such barriers may protect nonparticipating persons (observers, the public, news 

media, etc.) from debris in the event of an accident. 
18. If the UAS loses communications or loses its GPS signal, the UA must return to a 

pre-determined location with in the security perimeter and land or be recovered in 

accordance with the operator's manual. 

19. The UAS must abort the flight in the event of unpredicted obstacles or 

emergencies in accordance with the operator's manual. 

20. Each UAS operation must be completed with 25% battery power remaining. 

21. The operator must obta in an Air Traffic Organization (ATO) issued Certificate of 

Waiver or Authorization (COA) prior to conducting any operations under this petition 

of exemption. This COA wil l a lso require the operator to request a Notice to Airman 

(NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the 

operation. 

22. All aircraft operated in accordance with this exemption must be identified by 

serial number, registered in accordance with 14 CFR part 4 7, and have identification 

(N-Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must 

be as large as practicable. 

23. The operator must develop procedures to document and maintain a record of the 

UAS maintenance, preventative maintenance, alterations, status of 

replacement/overhaul component parts, and the total time in service of the UAS. 

These procedures must be added to the operator's manual. 

24. Each UAS operated under th is exemption must comply with all manufacturer 

Safety Bulletins. 

25. The operator must develop UAS technician qualification criteria. These criteria 

must be added to the operator's manual. 

26. The preflight inspection section in the operator's manual must be amended to 

include the following requirement: The preflight inspection must account for all 

discrepancies, i.e. inoperable components, items, or equipment, not covered in the 

relevant preflight inspection sections of the operator's manual. 

27. Before conducting operations, the radio frequency spectrum used for operation 

and control of the UA must comply with the Federal Communications Commission 

(FCC) or other appropriate government oversight agency requ irements. 

28. At least three days before scheduled infrastructure inspection, the operator of the 

UAS affected by this exemption must submit a written Plan of Activities to the local 

FSDO with jurisdiction over the area of proposed infrastructure inspection. The 3-day 

notification may be waived with the concurrence of the FSDO. The plan of activities 

must include at least the following: 

a. Dates and times for all tl ights; 

b. Name and phone number of the operator for the UAS infrastructure 
inspection operations conducted under this petition of exemption; 

c. Name and phone number of the person responsible for the on-scene 

operation of the UAS; 

d. Make, model, and seria l or N-number of UAS to be used; 

e. Name and certificate number ofUAS PICs involved in the infrastructure 

inspection event; 

f. A statement that the operator has obtained permission from propetty 

owners and/or local officials to conduct the infrastructure inspection event; 

the list of those who gave permission must be made available to the inspector 

upon request; 

g. Signature of exemption-holder or representative; and 

h. A description ofthe flight activity, including maps or diagrams of any area, 

city, town, county, and/or state over which infrastructure inspection will be 

conducted and the a ltitudes essentia l to accomplish the operation. 

29. The documents required under 14 CFR §§ 91.9 and 91.203 must be available to 

the PIC at the Ground Control Station of the UAS any time the aircraft is operating. 

These documents must be made available to the Admi nistrator or any law 

enforcement officia l upon req uest. 

30. The UA must remain clear and yie ld the right of way to all other manned 

operations and activities at a ll times (includ ing, but not limited to, ultra light vehic les, 

parachute activities, parasailing activities, hang gliders, etc.). 

3 I. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. 

A ll operations must be conducted under visual meteorologica l conditions(VMC). 

Flights under special visual flight ru les (SVFR) are not authorized. 

32. The UAS may not be operated by the PIC from any moving device or vehicle. 

33 . The UA may not be operated less than 500 feet be low or less than 2,000 feet 

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

34. The UA may not operate in Class B, C, or D airspace without written approval 

from the FAA. T he UA may not operate within 5 nautical miles of the geographic 

center of a non-towered a irport as denoted on a current FAA-published aeronautica l 

chart unless a letter of agreement with that a irport's management is obta ined, and the 

operation is conducted in accordance with a NOT AM as required by theoperator's 

COA. The letter of agreement with the airport management must be made avai I able to 

the Administrator upon request. 

35. Any incident, accident, or flight operation that transgresses the lateral or vertical 

boundaries of the operational area as defi ned by the applicable COA must be reported 

to the FAA's UAS 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. Further flight operations may not 

be conducted until the incident, accident, or transgression is reviewed by AFS-80 and 

authorization to resume operations is provided. 
Support for Petition for Exemption 

In accordance with the procedural requirements of 14 C.F.R. § 11.81, EagleEye Imagery, 

LLC provides the following information: 

Contact Information: 

Derrick Reid Stacy 

CEO and Managing Partner 

EagleEye Imagery, LLC 

2945 Peaks Mill Drive 

Lexington, KY 40511 

859-494-5694 

derrickstacy@gmail.com 

Regulatory Provisions from which EagleEye Imagery, LLC seeks an 

Exemption 

EagleEye Imagery, LLC believes it may need an exemption from the following 

provisions to conduct the contemplated operations. In some instances, relief is needed 

because relief from another provision renders compliance with the regulation at hand 

infeasible. 

333 Aircraft Exemption Status 

14 C.F.R. §61.113(a) and (b) 

14C.F.R. §91.119(c) 

1:4 C.F.R. §91.121 

14 C.F.R. §91. 151 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a)(l)&(2) 

14 C.F.R. §91.417(a)&(b) 

EagleEye Imagery, LLC believes an exemption is only needed from the abovelisted regulatory provisions. To the extent that the FAA believes that additional relief is 

required for EagleEye Imagery, LLC to conduct the operations described here, we 

request an exemption from any such regulatory provisions as well.3 

3 For example, 14 C.F.R. §91.4 17(a) imposes certain maintenance record keeping requirements "as 

applicable". Since none of the underly ing requirements (e.g., inspection intervals) can be met and will 

require an exemption, EagleEye Imagery, LLC believes a separate exemption should not be required for 

§9 1.417(a). 
The Extent of Requested Relief and the Reasons Relief is Needed 

Section 333 Aircraft Exemption Status: 

Section 333 ofthe Modernization Act authorizes the FAA to exempt aircraft from the 

requirement for an airworthiness certificate based on a consideration of the size, weight, 

speed, operational capability of the particular UAS, as well as its proximity to airports and 

populated areas. An analysis of these criteria demonstrates that the sUAS operated without an 

airworthiness certificate in the areas and under the conditions contemplated by EagleEye 

Imagery, LLC will be at least as safe, if not safer, than a conventional aircraft (fixed wing or 

rotorcraft) operating with an airworthiness certificate without the conditions proposed in this 

request. 

The sUAS is less than 55 lbs. ful ly loaded, carries neither a pilot nor passenger, and operates 

exclusively within a secured area. Unli ke other civil aircraft, operations under this exemption 

will be tightly controlled and monitored by the operator and observer. Operations will be 

conducted in compliance with the FAA and with loca l public safety requirements to provide 

security for the area of operation as is now done with conventional equipment, infrastructure, 

bridge and out building evaluation. These safety enhancements provide an expanded degree 

of safety to the inspectors over conventional operations. Lastly, application of these same 

criteria demonstrates that there is no credible threat to national security posed by the sUAS, 

due to its size, speed of operation, location of operation, lack of explosive materials and 

inability to carry a substantial external load. 

Given the size and limited operating area associated with the aircraft to be utilized by the 

Applicant, this meets the requirements of an equivalent level of safety under Part 11 and 

Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (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 UAS 

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 (fixed 

wing or rotorcraft) operating with an airworthiness certificate without the restrictions and 

conditions proposed. 
14 C.F.R. 91.119(c) 

§91.11 9 Minimum safe altitudes: General. 

Except when necessary for takeoff or landing, no person may operate an 

aircraft below the following altitudes: 

*** 

(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 to any person, vessel, vehicle, or 

structure. 

***** 

EagleEye Imagery, LLC submits that the only relief it requires from §91. 119 is 

from the minimum altitudes listed in paragraph (c). Relief is required from paragraph (c) 

for fixed wing operations because asset evaluation conducted at 500 feet or higher is 

insufficiently distinct to be meaningful. Since operations at tlus altitude also pose a 

heightened risk of collision with another aircraft, safety can only be assured through the 

grant of an exemption. The anticipated rotorcraft operations should be adequately 

addressed by paragraph (d) (1 ). Additionally, relief should not be needed from paragraph 

(a) because an emergency landing of the aircraft due to a power failure will not create an 

undue hazard to persons or property on the surface. As noted in the explanation of why 

an exemption will not adversely affect safety EagleEye Imagery, LLC's clients have 

exclusive use of the land over which the sUAS will be operated, and public access is 

restricted. It also has exclusive use of significant portions of land adjacent to the 

infrastructure and structures that will be the objects of evaluation and analysis. EagleEye 

Imagery, LLC's clients tightly control access to land and have the ability to assure that 

no individuals unassociated with the planned operations are on the affected land. As 

such, the risk of injury is minimal. EagleEye Imagery, LLC does not contemplate 

conducting operations over congested areas, so relief is not requested fTom paragraph 

(b). 

14 C.F.R. 9 1.121 

14 C.F.R. §91.121 Altimeter Settings 

This regulation requires 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." 

***** 

As the sUAS may not have a barometric altin1eter, but instead a GPS altitude read 

out, an exemption may be needed. An equivalent level of safety will be achieved by the 

operator, pursuant to the Manual and Safety Check list, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight. 

Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric 

data feed, wh ich downlinks from the aircraft to a ground-based on-screen display. This 

a ltitude information will be generated by equipment installed on board the a ircraft, using 

GPS triangu lation, or digita lly encoded barometric altimeter, or radio altimeter, orany 

combination thereof. Prior to each fl ight, a zero a ltitude initiation point will be established 

a nd confirmed for accuracy by the pi lot. 
14 C.F.R. 91.151 

§91.151 Fuel requirements for flight in VFR conditions. 

(a) No person may begin a flight in an airplane 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 normal cruising speed -

(I) During the day, to fly after that for at least 30 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 fl y 

to the first point of intended landing and, assuming normal cruising speed, to 

fly after that for at least 20 minutes. 

***** 

Operating the sUAS in a pre-defined area with less than 30 minutes of reserve 

fuel does not raise the type of risk contemplated by §91.151 , i.e., that an aircraft could 

run out of fuel in the event it has to be flown to an alternate airport or circle the planned 

airport in the event of unanticipated conditions. EagleEye Imagery, LLC does not intend 

to use the sUAS for point-to-point flights and will not operate the sUAS beyond visual 

line of sight. Nor will the sUAS require an airport in order to land. Rather, EagleEye 

Imagery, LLC will operate the sUAS using pre-planned flight paths (taking into account 

weather conditions) designed to allow the sUAS to fly to the point of intended landing. 

As such, there is no need for a time- based excess fuel requirement. Rather it should be 

sufficient to require only as much additional excess flight capacity as necessary to safely 

land the sUAS. We believe that a 25% battery reserve is more than sufficient to meet this 

objective. 
Appendix A 

Summary for Federal Register Publication 

Pursuant to 14 C.F.R. Part 11 , the following summary is provided for publication in the 

Federal Register should the FAA determine that publication is needed. 

Petitioner: EagleEye Imagery, LLC 

Sections of 14 C.F.R. Affected: 

333 Aircraft Exemption Status 

14 C.F.R. §61.113(a) and (b) 

14 C.F.R. §91.1 19(c) 

14 C.F.R. §91.121 

14 C.F.R. §91.151 

14 C.F.R. §91.405(a) 

14 C.F.R. §91.407(a) 

14 C.F.R. §91.409(a) 

14 C.F.R. §91.417(a)&(b) 

Description of Relief Sought: 

Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, I 4 

C.F.R., 61.11 3(a)&(b )), 91.119( c), 91.121 , 91.1 51, 91.405(a), 91.407(a), 91.409(a), and 

91.417(a)&(b) to conduct sUAS operations over EagleEye Imagery, LLC Client's owned 

or controlled land, solely during daylight hours, to assist in the safe evaluation and 

analysis of infrastructw-e and operations. In general, sUAS operations are intended to be 

conducted in areas remote from both congested areas and airports. The nature of 

operations anticipated by EagleEye Imagery, LLC requires that the sUAS be flown at 

relatively low altitudes. EagleEye Imagery, LLC expects that in most instances, the sUAS 

will be flown less than 75 feet from the highest structure along the path of the sUAS and 

in no instances will be flown higher than 400 feet above the ground. Accordingly, the risk 

of interference with other aircraft is minimal. 
Appendix B 

Specific ty pe(s), make, and model: 

D)/ Phantom 3 Professional 

-- \\\\\\ I '• 

_ ... 

Aircraft Weight (Including Battery And Propellers): 1280g 

Diagonal Size (Including Propellers): 590 mrn 

Max Ascent Speed: 5 rnls 

Max Descent Speed: 3 rnls 

,,,..,,... --

Hover Accuracy: Ye11ical: +/- 0.1 m (when Vision Positioning is active) or +/- 0.5 m 

Horizontal: +/- 1.5 m Max Speed 16rnls (ATTI mode, no wind) 

Max Altitude Above Sea Level: 6000 m 

Operating Temperature: 0°C to 40°C 

GPS Mode: GPS/GLONASS 

Camera Sensor: Sony EXMOR 112.3" Effective pixels: 12.4 M (total pixels: 12.76 M) 

Lens: FOV 94° 20 mm (35 mm format equivalent) f/2.8, focus at oo 

ISO Range: 100-3200 (video) 100-1600 (photo) 

Shutter Speed: 8s -1/8000s 

Image Max Size: 4000 x 3000 

Still Photography Modes: Single Shot 

Burst Shooting: 3/5/7 shots 

Auto Exposure Bracketing (AEB): 3/5Bracketed Frames at 0.7EV Bias 

Time-lapse Video Recording Modes: UHD: 4096x2160p 24/25, 3840x2160p 24/25/30 

FHD: 1920x 1 080p 24/25/30/48/50/60 
HD: l280x720p 24/25/30/48/50/60 

Supported SD Card Types: 

Micro SD: Max capacity: 64GB. Class 10 or UHS-1 rating required 

Max Bitrate of Video Storage: 60 Mbps 

Supported File Formats: Photo: JPEG, DNG 

Video: MP4, MOV (MPEG-4 

Operating Temperature: 0°C to 40°C 

Gimbal Controllable Range: Pitch -90° to +30° 

Stabilization: 3-axis (pitch, roll, yaw) Vision Positioning 

Max Velocity: Less than 8 m/s (when 2m above ground) 

Altitude Range: 30 cm-300 em 

Operating Range: 30 cm-300 em 

Operating Environment: Surface with clear pattern and adequate lighting (Lux > 15) 

Remote Controller Operating Frequency: 2.400 GHz-2.483 GHz 

Max Distance: 2000m (outdoors and unobstructed) 

Battery: 6000 mAh LiPo 2S 

Receiver Sensitivity (1 % PER): -101 dBm ±2 dBm 

Transmitter Power (EIRP): FCC: 20 dBm 

CE: 16 dBm 

Working Voltage: 1.2 A @7.4 V 

Battery Charger Voltage: 17.4 V 

Rated Power: I 00 W 

Intelligent Flight Battery Capacity: 4480 mAh 

Voltage: 15.2 V 

Battery Type: LiPo 4S 

Energy: 68 Wh 

Net Weight: 365 g 

Max Flight Time: Approximately 23 minutes 

Operating Temperature: -1 0°C to 40°C