August 1Oth, 20 15
Unmann e d Aircraft Systems Integration Office Federal Aviation Administration 800 Independence Avenue , S W Washington, DC 20591
U

. S. Department of Transportation , Docket Operation West Building Ground Floor, Room w12-140 1200 New Jersey A ve nu e , SE Washington , DC 20590

T o 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 s e veral provisions of T itle 14 of th e Code ofF ederal R e gulations (C.F.R.) to permit the u s e of
sma ll unmanned aeria l system s (sUAS) to provide aerial photography**an~** video , as we ll
a s to ass is t in the evalu ation of in fras t ructure and operati ons for our clients. This reque s t is motivated primarily by the desire to max imize safety in infrastructure and operations. An exemption would allow A.l. to broad ly evalu ate assets and operations with s UAS , resulting in a safer and more e fficient infrastructure network. Accordingly , th e grant of
an exemption is consistent with Congress ' intent , reflecte d 'in Section 333 of th e FAA Moderni z ation and Reform Act of2012 (Mod e rni z ation A ct) , 1that safe sy s tems be permitted in the national a ir s pace prior to the i s suanc e of final regulations govern in g general use of these systems

. 2 A s ummary of thj s reque s t suitab le for publication in the Federal Register is provided as Appendix A. Appendix B pro v ides the manufacturer s information re g arding the design , a ircraft pe r formance , and fail-safe features. We have provided manufacturer information related to operating limitations , normal and emergency pro cedure s, and maintenance and in s pecti o n procedures. A s we add aircraft d e si g n s, we wil l update this append ix appropriate l y. Appe nd ix C pro v ides the EagleEye Imagery , LLC Operation s Manual for flight s covered und e r th is Exemption Requ e st. 

## ' 1 P.L. 112- 9 5, 126 S tat II. Fe bruar y 1 4, 20 12. 2 Sec ti o n 333( b) (2) s p ec ifi ca ll y co nte mplates that th e F AA m ay i ss ue a ce rtifi c at e o f w a i ve r up o n a findin g th a t a ty pe o f UAS, as a r es ult o f it s s ize, we ig ht , s p eed , o pe r a ti o n a l capac i ty, prox imity to airp o rt s a nd p o pulate d a r e a s. a nd
o pe rati o n s within v is ual lin e o f s i g ht d o n o t c r e ate a haza rd to u se r s of the NAS o r th e public o r p ose a threa t t o nati o n a l
sec urit y.

### 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 irreducibl e element of risk involved whenever emp l oyees are required to go out on structures

. Em p loyees may need to climb over or onto structures, whic h can be s lippery , rough , and/or exposed to the elements. Some structures, such as bri dges , are high above the ground. Equipment moving through inspection zones can i ncrease risk as well, especially in high-traffic areas. While th e use of sUAS for supplemental infrastructure and general asset evaluation would not e li minate these risks entirely (as it is an additive safety measure) , it would reduce the risks to employees by allowing for remote ae ri a l review. Additionally , the sheer amount of assets and the w idely dispersed locations

- in many instances far from sizeable population centers

- means that visual inspection in a ll i n stances by company personnel can be inefficient. Aerial anal ysis by traditional fixed wing aircraft is impractical because the required altitudes for safe fl ight reduce v isibility below meaningful leve l s- it is sitr.ply not possib le to see all asset anomali es from such heig hts. 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 dep loyment. By using sUAS for supp le mental asset eval uation , EagleEye Imagery, LLC will be able to substantia ll y upgrade its capac ity to detect and address issues with th e right-of-way and other assets before they become a problem for safe operations. T hus , the use of sUAS has the potential to improve efficiency, res ulting in faster and safer de livery of goods, energy & 

### natural resources vital to t he U .S. economy
.

### G r a nting an Exemp ti on w ill not A dverse ly Affec t Safety 

### EagleEye Imagery , LLC notes that there is no applicable standard for an equ ivalency 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 allowab l e operations for model aircraft. We believe it is difficu l t to argue that there is suffic ient co rre lation between model operations controlled by the Academy of Model Aeronautics and the ones contemplated by EagleEye Imagery , LLC

. At the same t ime , it is clear that equival ency cannot be established for trad it ional, manned c i vi l a i rcraft because the design and use profiles between trad itional aircraft and sUAS are simply too different. As such , we be lieve it makes more sense to foc u s on why the contemplated operations wou ld not adversely affect safety , wh ich is a ll that §11.81(e) requires. Granting an exemption w i ll not adve rsely affect safety. EagleEye Imagery, LLC contemplates conducting sUAS operations over client owned or contro ll ed land , solely duri n g dayl ight hours , at altitudes we ll below 200 '

. ln genera l, 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 , e levated , 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 E agleEye Imagery , LLC requires that the sUAS be flown at relative l y low alt itudes and re lati vely l ow speeds. EagleEye I magery, LLC expects t hat in most instances , the sUAS will be flown less than 100 feet from t he highest structure along the path of the sUAS. Accordingly , the risk of interference with another aircraft is min i mal. EagleEye Imag ery , LLC a l so plans to conduct sUAS operat ions at least three miles from any publ ic airports (includ ing heliports). In the event an operation needs to be conducted c l oser to an a ir port , EagleEye Imagery , LLC will inform the airport operator and airport air traffic conh·ol tower of the contemp lated operation and will comply with any directions issued by air traffic control at that airport. Approva l of exemptions allowing commercial operations of sUASs in the infrastructure aerial inspect ion industry wi ll enhance safety by reducing risk. Conventional operat ions , using jet o r piston power a ircraft , operate at extreme l y low altitudes just feet from the subject be ing inspected and in extreme proximity to people and stmctures; and present the risks assoc iated with ve h icles that weigh in the neighborhood of 4 ,000 1 bs., carrying large amounts of jet A or other fue l ( 140 gallons for j e t helicopters). Such aircraft must fly to and from the inspection site. In 

### contrast , a sUAS weighing fewer than 55 lbs. and powered by batteries e l iminates virtually all of that risk given the reduced mass and lack of combustible fue l can· i ed on board. The sUAS is carried to the inspection site. The sUAS wi ll carry no passengers or crew and , therefore, wi ll not expose them to the risks associated with manned aircraft flights.
The operation of small UASs , weighi ng less than 55 lbs. , conducted in the strict cond it ions outlined above , will provide an equivalent leve l of safety supporting the grant of the exemptions requested herein , including 333 Aircraft Exemption Status exempting the appl icant from conventional aircraft requirements and allowing commercialoperating area. Should there be a mishap , the sUAS being flown pose significantly less of
a threat than the helicopters and fixed wing aircraft now be ing emp l oyed because they are a fraction of the size, carry no flammable fue l , 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 explos ive fuel , carry passengers and crew, and operate in a much larger area
.

From a practical standpoint, there are relative ly few licensed full

- scale aircraft pilots who
are a lso 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 un l ikely for a company to find a pilot that has both quali ficat i ons , that company wou l d either have to source a qualified sUAS p ilot to train and obta in a commercial certificate , or find a comme rc ia l cert ificated pilot who would be wi lling to learn to fly a sUAS to the competency level requ ired for professional use.
Minimum requirements for the PIC include: 1) A minimum of200 flight cycles and 25 hours oftotal time as a sUAS rotorcraft p il ot; 2) A min imum of 5 hours as sUAS pilot with the make and model of sUAS to be ut i lized for operat ions 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 ai rcraft 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 shou ld ameliorate security concerns over UAS operations und e r this exemption. EagleEye Imagery , LLC intends to use commercially available sUAS Components for sUAS. These sUAS systems will be tested for qua lity & safety in our test faci l ity before being dep l oyed 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
mai ntenance schedule to verify that the sUAS wi ll rema in in safe and operational condition. Please see Ap pe ndi x 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 Cons iderations: Best-in-class , tr ied and proven tech n o log ies t hat are in advanced ite rat ions. Softwa re fr om h ighly-reputab le industry partners will include feat ures
- I. Auto descent (landing) if communicat io n signal were to be seve red

. If the sUAS loses comm un ications, the sUAS wi ll have capabil ity to return to a pre-determined location within the Secur i ty Perimeter and l a nd. 2

. A uto descent (landing) if battery we re to drop lower than nominal level. 3

. F li g h ts w ill be term in ated at 25% battery power reserve. 4. Live video fo r ope rato r g ives real-time positioning feedback. In other words , we can m on it or the scene from the veh icle's perspective for co lli sion avo idance , and to maintain spatia l or ientation. 5. The sUAS will have the capabil ity to abort a flight in case ofunpred icted obstacles
or emergenc ies. 6. O n- Sc reen-D isplay (OS D ) contains operat in g information to ascertain veh icl e health at a ll times: speed , a ltitude , n umbe r ofG P S sate llites (when ava il able) , head in g a nd vo l tage. 7

. GPS lock supplies for return- to-home (RTH). Should Command and Contr ol (C2) link fa il ures occu r ( hi gh ly improbable) , ve hi cle ret urn s a utomat ically to the point of la un c h

. 8

. A lti tude information wi ll be prov id ed to the sUAS p il ot v ia a d igitally encoded telemetric data feed , w hi ch downlinks from the a irc raft to a gro und -based on-screen display. Thi s altitud e information w ill be generated by equ ipm e n t in sta ll ed on board t he airc raft , using GPS triangulation, or d ig i tally encoded barometri c alt im eter, o r radio a ltime t er , or any comb in ation thereof. Prior to each flight , a zero a lt itude in it iat io n point w ill be estab li s h ed a nd confirmed fo r accuracy by the pi lot.
Mechanical /Physical: I. EagleEye Imagery , LLC w ill fl y lin e-of-sight (LOS) o n ly. The veh icle wi ll a lways remain in d i rect LOS to the pilot , thus eliminati ng the concern of signal severa nce (fly in g be hind objects / walls)

. 2. The sUAS w ill we ig h less tha n 55 lbs and travel at less than 50 knots. 3. Batteries s hou ld far exceed the capacity requi red for actu al flight time. 4. Fli ghts will be operated at an alt itud e of no more than 400 feet AG L. 5

. Fir eproof bags for sto rage and cha rg in g of high capacity Lip o batter ies 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 ens ur e safe operc.tion and act as a redundant set of eyes for operators (p il ot , g imb a l op , d irector) 2. Radio spectrum a nalysis for inte r fere nce on the frequencies util ized for vehicle contro l / commun ication

. 3. A briefing will be cond ucted in regard to the planned sUAS operations priorto each day ' s act ivities

. It will be mandatory that a ll personnel who will be perform in g duties with in th e bo un daries of the safety perimeter be present for th i s bri efing. 4. The operator will obtain the consent of all pe r sons involved in the sUAS operationsa nd ensure that only consenting persons will be al lowed with in I 00 feet of the flight operations. 5. Observer and pi lot will at all t imes be able to comm un icate by vo ice. 6. Writte n and/ o r oral permiss ion from the relevant property ho lders wi ll be obtained. 7. Pi lot and observer w ill have been trained in operation of UAS generally and
rece ived u p-to

- date informat ion on the part icu l ar UAS to be operated. Operations: I. T he 

### unmanned aircraft (UA) must weigh less than 55 pounds (25 Kg) , includ i ng energy source(s) and equipment. Operations authorized by this petition of exemption are limited to the fo ll owing airc r aft descr ibed in Appendix B. Proposed operations of any other aircraft will requ ire 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 t imes
. This requires the PIC to be able to use human vision unaided by any device other than correct ive l enses , as specified on the PIC ' s FAA-issued med ical certificate.
5. All operations must uti li ze a visual observer (YO)

. The YO may be used to sat isfy the YLOS requirement as l ong as the P IC always maintains YLOS capability. The YO and PIC must be able to comn1lmicate verbally at a ll times

. 6

. The operator's manual included as Appendix C and t hi s petition of exemption must be maintained and made available to the Administrator upon request. If a d iscrepancy exists between the conditions and limitations in th is exemption and the procedures outlined in the operator ' s manual, the cond itions and li m itat ions 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 responsib ili ty to track such revisions and present updated and revised documents to the Administrator upon request. The operator must also present updated and rev i sed documents if it petitions for extension or amendment. If the ope rator 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 exempt ion. The FAA ' s UAS Integrat ion 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 i t is in a cond ition

### for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS , the ai rcraft i s prohibited from operatin g 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 utili zed , must be in cl ud ed in the prefl ight in spect i on. A ll maintenance and a lterations must be properly documented in the aircraft reco rd s.
8. Any UAS that has undergone maintenance or alterations that affect t he UAS operation or flight characteristics , e.g. replacement of a flight critic a l co mp onent , 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 fo r a functional test flight and ai rc raft 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 , a ircraft maintenance/ component/overhau l, r eplacement , and in spection / maintenance r equirements must be establ i shed and identified in the operator ' s manual. At a minimum , r equi r ements for the fo ll owing must be in cluded in the operator's manual:
a. Actuators 

### I Servos; b. Transm ission (single r otor); c. Powerplant (motors); d. Propellers; e. El ectronic speed controller ; 

### f. Batteries; g. Mechanical dynamic components (single rotor); h. Remote command and control; i. G r ound contro l station (if used); and j

. 

### Any other components as determined by the operator;
I 

### 0

. The PIC must meet the flight review requirements spec ified in 14 CFR 

### § 6 1. 56 in an a ircraft 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 l east 10 hours l ogged as a UAS pilot with a similar UAS type (sing le blade or multirotor). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training , proficiency , and experience-bui ldi ng flights can also be conducted under this petition of exemption to accomplish the requ ired flight cyc les and flight time. During training, proficiency , and experience-bui ld ing flights , all persons not essential for flight operations are cons id e r ed nonparticipants , and the PIC mustoperate the UA with appropriate distance from nonpartic ipan ts i n accordance ·with 14 CFR 

### § 9 1. 1 1 9

. 12. P rior to operations conducted for the purpose of i nf ras tructu re i nspect io n , t h e PIC m u st have accu mu l ated and logged , in a manner cons i stent w ith 14 CFR 

### § 6 1 .51(b), a m inim um offive hours as UAS p il ot operati ng the make and model of UAS to be utili zed for operations under the exemption and three take-offs and three landings in the preceding 90 days. Training , proficiency , experiencebu ilding , and take

- off and landing cunency flights can be conducted under th i s petition of exempti on to accomp l ish the required flight time and 90 day cu rrency
. During training, profic iency, experience-bu ilding , and take

- off and land ing cunency flights all persons not essentia l for flight operat io n s are cons idered nonparticipants , and the PIC must operate the UA w it h app rop r iate d i stance from nonpartic i pan ts in acco r dance w i th 14 CFR 

### § 9 1.1 19.
13. Prior to any fligh t operations authorized by this petition of exemption, the PIC and YO must have successfully completed a q u alification process , as outl ined in the operator's manual. As this is a requ ireme n t stipu l ated by the operator , the test must be deve loped and imp l emented by a qualified person designated at the sole d i scret ion of the operator. A record of completion of this qualificat ion process must be documented and made avail able to the Administrator upon request.
14. P ri o r to ope rat i ons conducted for t he purpose of inf rastructu re inspect i on , a fl i ght demonstratio n , admin isterea by an operator-approved and -qua li fied p il ot must be successfu ll y completed and documented. T his documentation must be ava il ablefor review upon request by the Adm in istrator. Because the knowledge a n d a irmansh ip test qua li fications have been developed by the operator, a nd there are no es tabl ished p ract i ca l test standards th at suppo r t a ju r isdictiona l FAA rSDO evaluation and a p p r oval of company des i gnated exam iners , the petitioner wi ll conduct these tests in accordance with the operato r ' s ma nual.
15. T he UA may not be operated direct l y over any pe rson , excep t autho ri zed a nd consent ing person nel , below an alt i tude th at is hazardous to pe rsons or property on the surface in the event of a UAS fai lur e or emergency.
16. Rega r d in g the dista nce from part i cipat ing pe r so ns , the o pe rator's manual has safety mit i gatio n s fo r authorized and consent ing person nel. At all time s, those pe r so ns m u st be esse nt ial to the ope rations.
17

. R egarding d istance from nonparticipating pe r sons, the operato r m ust ensu re that no pe r sons are a ll owed w i th in 500 feet of the area except those consenti ng to be in volved and necessary for the inf rastructure inspection ope rations. Th is provis i o n may be reduced to no less tha n 200 feet if it wo u ld not adversely affect safety and the Adm in i strator has approved it. For examp l e , an equivalent l eve l of safety maybe determ ined by an aviation safety ins pector's evaluation of the infrastructure inspection area to note terrain features, obstructions , build ing s, safety barri ers , etc. Suc h barri ers may p rotect nonparticipating pe r sons (observers , the pub l ic , news med ia, etc

.) from debris in the event of an accident.18. If the UAS loses commun ications or loses its GPS s ignal, the UA must return to a pre-determined location with in the security pe rim eter and land o r be recovered in accordance with the operator's manual.
19. The UAS must abort the flight in t h e event of unpredicted obstacles o r eme rge ncies in accordance with the operator's manual.
20. Each UAS operat ion must be completed with 25% battery power remaining.
21. The operator must obta in an Air Traffic Organization (ATO) issued Certificate of Waiver or Autho ri zation (COA) p ri or to conducting any operat ions under this petition of exemption. This COA w il l a l so require the operator to request a Notice to Airman (NOT AM) not more t han 72 hours in advance, but not l ess than 48 hours prior to the operation.

22

. All aircraft operated in acco rdanc e w ith thi s exempt io n must be identified by serial number , registered in accordance with 14 CFR part 4 7 , and have identification (N-Number) marking s in accordance with 14 CFR part 45, S ubpart C. Marking s must be as large as practicable.
23. The operator must develop procedures to document and maintain a record of the UAS maintenance , preventative maintenance , alte r ations, statu s of replacement/ove r haul component parts , and the total time in serv ice of the UAS. T he se procedures must be added to the operator's manual.
24

. Each UAS operated under th is exemption must comply w ith all manufacturer Safety Bulletins.
25

. The operator mu st develop UAS technician qualification c riteria. These criteria must be added to the operator ' s manual.
26. The preflight inspection sec tion in the operator's manual mu st be amended to include the following requirement: The preflight inspection must account for all discrepancies , i .e. inoperab le 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 contr o l of the UA must comp l y with the Federal Co mmuni cations Commission (FCC) o r other appropr iate government oversight agency requ irements

. 28. At l east three days before schedu l ed in frastructure in spection , the operator of the UAS affected by this exe mp tion must submit a w ritten Plan of Activities to the local FSDO w ith jurisdiction over the area of proposed infrastructure in s pection. The 3-day notification may be waived with the concurrence of the FSDO. The plan of activit ies must include at l east the fo ll owing:

a. Dates and t im es for all tl ights; 

### b. Name and phone number of the operator for the UAS infrastructureinspection o p erations conducted und er t hi s petition of exemption ; c
. Name and phone n umb er of the pe r son responsible for the o n-scene operat io n of the UAS ; d. Make , model , and se ri a l o r N-number of UAS to be used ; e. Na m e and certificate numb er ofUAS PI Cs involved in t he infrastru ctu re inspection event; f. A state m ent t h a t t he ope rator has obtained permission from propetty owne r s and/ o r local officials to conduct t he inf r astru cture in spection event ; the list of those w ho gave permiss io n must be made ava il ab l e to t he inspecto r upon req u est ; g. S ignature of exemp ti o n -holder o r representat ive ; a nd h. A descr ipti on ofthe flight act ivity , including m aps or diag r a m s of any area , c ity , tow n , county , and/ or state ove r w hich inf ras tru cture in spect ion will be conducted and the a lt itudes essentia l t o acco m p li s h th e ope rat io n.
29. The documents req u ired und er 14 CF R §§ 91.9 and 91.203 must b e ava il ab l e to the P IC at the Ground Contro l Stat ion of t he UAS any tim e the ai rc r aft is ope r ating. These documents must be made avai lable to t he Admi ni strator or any law enforcemen t offic ia l upon req uest.
30. The UA must remain clea r and y ie ld the right of way to al l othe r manned opera ti o n s a n d activities at a ll times ( inclu d in g, but not l imited to , ultra li g h t ve hi c l es , parachute act ivit ies , parasailing act ivit ies , hang gliders , etc.).
3 I. UAS ope ra t ions may no t be co ndu cted dur ing n ight , as defined in 14 C FR § 1

. 1

. A ll operat ions mu st be co ndu cted und er v isual meteorologica l cond iti ons(VMC). Flights under spec ial v isua l flight ru l es (SV FR ) are n ot a uthorized

. 32. Th e UAS may not be operated by the PI C fr om a ny m ov in g device or ve h ic l e.
33

. T he UA may not be ope r ated less tha n 500 feet be low or less than 2 , 000 feet ho ri zonta ll y from a clo ud or w h en v i s ib ili ty i s less t ha n 3 statute m il es from the PI C.
34

. The UA may not operate in C lass B , C, o r D airs p ace w it ho ut written approva l from the FAA

. T he UA m ay not operate w ith in 5 nautical m i les of the geograp hi c ce nte r of a non-towered a irport as denoted on a cu rr ent FAA-pub l ished aeronautica l chart unless a letter of agreement w i th t hat a irport ' s management is ob t a in e d , a nd the ope r at io n i s conducted in accordance with a NOTAM as req uired by theoperator ' s COA. Th e lette r of ag reeme n t with the airport management mu st be made ava i I able to the Adm ini strator upon request.
35. Any incident, acc ident , or flight operation that tr a n sg resses the lateral or vert ica l boundaries of the operational area as d efi ned by the app l icable COA must be repo rted to the FAA ' s UAS In tegrat ion Office (AFS

- 80) with in 24 h ou rs
. Acc idents must be
re p orted to the Nat ional T ransportation Safety Board (N T SB) per in st ru ct ions co ntain ed o n the NTSB Web s ite: www
. ntsb.gov. Furthe r flight operat io n s may not be conducted until the inc ident , accident, or transg ression is reviewed by AFS-80 and author ization to resume operati ons is provided.

### S upp ort for Pet i tio n fo r Exe mp t ion In accordance with the procedural requirements of 14 C.F.R. § 11.81 , EagleEye Imagery , LLC provides the fo ll owing information:


### Co nt act I n f orm atio n : Derr i ck Reid Stacy CEO and Managing Partner Eag l eEye Imagery , LLC 2945 Peaks Mill Drive Lexington , KY 40511 859

- 494

- 5694 derrickstacy @ gmail.com


### Re gul ato ry Prov i s ions fro m w hi ch Eag leEye I m a gery, LLC seeks an Exe mptio n EagleEye Imagery , LLC be li eves it may need an exemption from the following provisions to conduct the contemplated operat ions
. In some instances , relief is needed because re l ief from another prov ision renders compliance with the regu l ation at hand infeasible. 333 Aircraft Exe mption 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. §9 1. 151 14 C.F.R. §9 1. 405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a)(l)&(2) 14 C.F.R. §9 1. 417(a)&(b) EagleEye Imagery , LLC believes an exemption is only needed from the above

listed regulatory provisions. To the extent that the FAA be lieves that additional relief is required for EagleEye Imagery , LLC to conduct the operations described here , we request an exemption from any such regulato r y 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 under ly ing requirements (e.g., inspection interval s) 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 Req u ested Re li ef a n d the Reas on s R eli ef is Needed
Section 333 A ircraft Ex emp t ion Stat u s: Section 333 ofthe Modernization Act authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate based on a conside ration of the size , we i ght, speed , operational capabi l ity of the particular UAS , as we ll 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 contemp lated by EagleEye Imagery , LLC will be at least as safe, if not safer, than a conve ntiona l airc raft (fixed w ing or rotorcraft) operating with an a irwo rth iness cert ificate without the conditions proposed in this request.
The sUAS is less than 55 lbs

. ful l y loaded, carries neither a pilot nor passenger, and operates excl u sively w ithin a secured area
. Un li ke other civ il aircraft, operations under th is exempt i on wi ll be tight l y controlled and monitored by the operator and observe r
. Operations w ill be conducted in compliance with the FAA and with l oca l publ i c safety requirements to prov ide security for the area of operat i on as i s now done w ith conventional equipment , infrastructure , bridge and out bui l ding evaluation. These safety enhancements provide an expanded degree of safety to the inspectors ove r conventio nal ope rations. Lastly , app li cation of these same criteria demonstrates that there i s no credible threat to national secu r ity posed by the sUAS , due to its size, speed of operation, location of operat i on , lack of explosive materials and inabi l ity to carry a substantial externa l l oad.
G i ven the size and limited operating area associated with the aircraft to be utilized by the Applicant, this meets the requirements of an equ ivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U

. S.C.§4470 1 

### (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement for an a i rworthiness certificate , upon consideration of the size , weight , speed , operational capabi l ity , 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 cond itions proposed w ill 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 M inimum safe altitud es : G en er al. Except w hen necessary for takeoff or landing , no person may operate an ai rcraft below the following altitudes: 

### *** (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely popu lated areas. In those cases , the aircraft may not be operated closer than 500 feet to any person , vesse l , vehicle, or structure. 

### ***** EagleEye Imagery , LLC submits that the only relief it requires from §9 1. 119 is from the min im u m altitudes l isted in paragraph (c). R e l ief is required fr om paragraph (c) for fixed wing operations because asset evaluat ion co nd ucted at 500 feet or higher is insufficiently distinct to b e mean ingfu l. Since operations at tlus altitude also pose a heightened r isk of co lli s ion with another ai rcraft, safety can only be assured through t he 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) becau se an emergency landing of the aircraft due to a power fail ure will not create an undue hazard to persons or property on the surface

. As noted in the explanati on of why
an exemption will not adve r sely affect safety EagleEye Imagery , LLC's clients have exclusive use of the land over wh ich the sUAS will be operated , and public access is restricted

. 

### It also has exclus ive use of significant portions of land adjacent to the infrast r uctu re and structures that will be the objects of evaluation and analysis. Eag l eEye Imagery , LLC's cl i ents tightly contro l access to land and have the ability to assure t hat no indiv iduals unassociated with th e planned operations are on the affected land

. As such, the ri sk of in j ury i s minimal. EagleEye Imag e ry , LLC does not contemplate conducting operations over congested areas , so relief is not requested fTom paragraph (b).
14 C.F

. R. 9 1. 121 

### 1 4 C.F

. R. §91. 1 2 1 Altim et e r Settin gs T hi s regu lation requi r es each person operating an aircraft to ma intai n cru ising altitude by reference to an altimeter that is set "

.. . to the e levation of the departure airport or an appropriate al timeter setting available before departure. " 

### ***** As the sUAS may not have a barometric a ltin1eter, but inste ad a GPS a ltitude read out, an exempt i on may be needed

. An equivalent l evel of safety wi ll be ach ieved by the operator , pursuant to the Manual and Safety Check list , confirm ing the altitude of the launch s ite shown on the GPS altitude indicator before flight. Alt i tude information w i ll be provided to the sUAS pi lot via a digita ll y encoded telemetric data feed , wh ich downlinks from the ai rcraft to a ground-based on-screen display. This
a ltitude info rmat io n will be gene rated by equipment insta ll ed on boa rd the a irc raft , us in g GPS triangu latio n , or digita ll y encoded barometric altimeter, or radio altimeter, orany combinat ion thereof

. P ri or to each fl ight, a zero a ltitude init i at io n point will be established
a nd confi rmed 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 un less (cons id ering win d and forecast weather conditions) the r e is enough f uel to fly to the first point of intended landing and , assum in g normal cr ui si n g speed

- (I) Durin g t h e day , to fly afte r that for at le as t 30 minutes. (b) No person may begin a fli g ht in a r otorc raft under VF R conditio ns unless (co ns id erin g wind and forecast weathe r co ndi ti ons) there is enough fue l to fl y to the first po int of intended landing and , assuming normal cruising speed , to fly afte r that for at l east 20 minutes. 

## ***** Operating the sUAS in a pre
- defined area w i th less than 30 mi n utes of reserve fue l does not raise the type of risk co ntemp lated by §9 1.151 , i. e
. , that an ai rcraft could run out of fuel in the event it has to be flown to an alternate a irp ort or circle the planned a irp ort in the eve n t of unanticipated conditions. Eag leEye Imagery , LLC does not intend to use the sUAS fo r point-to

-point flights and will not op erate th e sUAS beyond v is ual lin e of s ight. Nor will the sUAS re qui re an airport in order to land

. Rather , Eag leEye Im agery , LLC w ill operate th e sUAS using pre-planned fli g ht paths (tak in g into account weather conditions) designed to allow th e sUAS to fly to the po in t of intended l anding. As su ch , there is no need for a t ime- based excess fuel requirement. Rather it should be sufficient to requ ire on ly as much ad diti onal excess flight capacity as necessary to safely l and the sUAS

. We be li eve that a 25% battery reserve is more than suffic ient to meet th is ob

j ect ive
.

### A pp e ndi x A 

### Summary for Federal Register Publication
Pursuant to 14 C

. F.R. Part 11 , the fo llowin g s umm ary i s provided for publication in the Federal Register should the FAA determ ine that pub li cation is needed.
P etitio n er: Eag leEye Imagery , LLC

Section s of 14 C

. F

. R

. Affected: 333 Aircraft Exemption Status 14 C.F.R. §6 1.11 3(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. §9 1.405(a ) 14 C.F.R. §9 1.407 (a) 14 C.F. R. §91.409(a) 14 C.F. R. §9 1 .417(a)&(b)
D escription of Relief Sought:
Petitioner seeks relief from th e requirements of 333 Aircraft Exempt ion Status, I 4 C.F.R. , 61.11 3(a)&(b)) , 91.119( c) , 91.121 , 9 1.1 5 1 , 91.405(a) , 9 1. 407(a) , 91.409(a) , and 91.417(a)&(b) to conduct sUAS operation s over Eag l eEye Imagery , LLC C li ent ' s owned or controlled land , so lely during day li ght hours , to ass ist in the safe evaluation and a nal ys is of i nfrastructw-e and operations. 

### In general , sUAS operations are intended to be conducted in areas remote from both congeste d areas and airports

. The nature of operations anticipated by Eagle Eye Imagery , LLC requires that the sUAS be flown at re latively low altitudes

. EagleEye Imagery , LLC expects that in most instances , the s U AS will be flown less than 75 feet from the high e st structure along the pat h of the sUAS and in no in stances w i ll be flown higher than 400 feet abov e th e ground. Accordingly , the risk of in terference with other aircraft is minimal.

### Appendix B Specific t y pe(s), make , and model: 

## D)/ Phantom 3 Professional



# -- \\\\\\ I '•



# _ ...

Aircraft Weight (Including Battery A nd Propellers): 1 280g Diagonal Size (Including Propellers) : 590 mrn Max Ascent Speed: 5 rnls Max De s cent Speed: 3 rnls 

# - - ,,,.., ,...

Hover Accuracy: Ye11ical: + /

- 0.1 m (when Vision Positioning is act ive) or +/

- 0

. 5 m Ho ri zontal: +/

- 1. 5 m Max Speed 1 6rnls (ATT I mode , no wind) Max A ltitude Above Sea Leve l: 6000 m Operating Temperature: 0 ° C to 40 ° C GPS Mode: GPS/ GLONASS Ca mera Sensor: Sony EXMOR 112.3" Effective pixels: 12.4 M (tota l pixe l s : 12.76 M) Lens: FOV 94° 20 mm (35 mm format equivalent) f/2.8 , foc us at oo ISO Range: 100-3200 (video) 100-1600 (photo) S hutter S peed: 8s -1 / 8000s Image Max Size: 4000 x 3000 S till Photography Modes: Single Shot Bur s t Shooting: 3/5/7 shots Auto Exposure Bracketin g (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: l 280x720p 24/ 25 / 30 /48 / 50 / 60 S upp orted SD Card Types: Mic r o SD: Max capacity: 64GB. Class 1 0 or UH S-1 ratin g required Max Bitra te of V id eo Storage: 60 Mbp s S upported Fi le Formats: Photo: JPEG , DNG Video: MP4 , MOV ( MP EG-4 Operating Temperature: 0 ° C to 40 °C Gimba l Co nt ro ll ab le Range: Pitch -90 ° to + 30 ° Stab ili zation : 3-axis (pitch, roll , yaw) Vision Positioning Max Velocity: Less th an 8 m /s (when 2m above ground) A ltitud e Ran ge: 30 cm
- 300 em Operating Range: 30 cm-300 em Operating Env ironment: Surface with clear pattern a nd adequate li g hting (Lux > 15) Remote Contro ller Operating Frequency: 2 .400 GH z -2.483 G H z Max Distance: 2000 m (ou tdoors and unob structed) Battery: 6000 mAh LiPo 2S Receiver Se n s itiv i ty (1 % P ER): -101 dBm ± 2 dBm T ran s mi tter Power 

### (E IRP ): FCC: 20 dBm CE: 16 dBm Working Vo ltage: 1 .2 A @ 7.4 V Battery C har ger Vo lt age : 17.4 V Rated Power: 

### I00 

### W Intelligent F li g ht Battery Capacity: 4480 mAh Voltage: 1 5.2 V Battery Ty p e: LiPo 4S Energy : 68 

### Wh Net Weight: 365 g Max F li ght Time: Approximately 23 minutes Ope r at in g Temperat ur e : -1 0 ° C to 40 ° C