1 March 19 , 2015

U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue, SE Washington, DC 20590

Re: Exemption Request ; Section 333 of the FAA Modernization & Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103 ; 91.109; 91.119; 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Ma dam,

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (“Reform Act”) and 14 C.F.R. 11, Advanced Robotics Corporation (“Petitioner”) hereby applies for an exemption from Federal Aviation Regulations (“FARs”) to allow commercial operation of small un manned aircraft systems (“sUAS”) in airspace regulated by the Federal Aviation Administration (“FAA”) for use in a variety of commercial applications so long as such operations are conducted within and under the conditions outlined her ein or as may be established by the FAA as required by Section 333.

As described more fully below, the requested exemption would permit the commercial operation of sUAS under con t r olled conditions in airspace that is : 1) limited; 2) predetermined ; and, 3 ) controlled as to access. The exemption would also provide safety enhancements to the safe operations currently performed by those presently using conventional manned aircraft. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “

... .establish requirements for the safe operation of such aircraft systems in the national airspace system. ” Section 333(c) of the Reform Act.

1. Name and A ddress of the Petitioner

Advanced Robotics Corporation Attn: David M. Garrett 5901 E. Lippizan Way Hereford, AZ 85615 Tel: 520.227.1865 Email: david.garrett@msn.com2 2. Company Background

Advanced Robotics is a non

- profit corporation based in Arizona specializing in education, knowledge and solutions supporting development and application of Unmanned Aircraft Systems and robotics to satisfy Government and C ommer c i al needs. Our program assists in public awareness for new career paths and education track s that are new and evolving resulting through crossover technologies of robotics, air, ground and water. Following approval of th is exemption request would enable Advanced Robotics the use of our sUAS to conduct operations within a variety of industry and business applications such as Education and Training, A erial Survey/Inspection and Imaging, Agricultural, Forestry, Wildlife Preservation, Law Enforcement, and Search and Rescue, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Petitioner is staffed with personnel who hold Airline Transport Pilot (ATP), Certified Flight Instructor (CFI)

– Instrument (CFII), Commercial, Instrument, and Private Pilot ratings, Airframe and Powerplant (A&P) Licenses . The Petitioner has extensive experience in UAS flight/payload operations, training

, and mainten ance of UAS for the US Army.

This airma n , and UAS knowledge and experience will be leveraged to maintain and enhance user and public safety throughout all aspects of unmanned aircraft (UA) ground and flight operations conducted by Advanced Robotics upon approval of this exemption request.

3. Regulations fro m which the exemption is requested , If such regula tions apply to sUASs. 14 C

. F

. R

. P a r t 21; 14 C

. F

. R

. 4 5

. 23 ( b ) ; 14 C

. F

. R

. 6 1

. 113 ( a ) & ( b ) ; 14 C

. F

. R

. 9 1

. 7 ( a ) ; 14 C

. F

. R

. 9 1

. 9 ( b )( 2 ) ; 14 C

. F

. R

. 9 1

. 103 ; 14 C

. F

. R

. 9 1

. 109; 14 C

. F

. R

. 9 1

. 119; 14 C

. F

. R

. 9 1

. 121; 14 C

. F

. R

. 9 1

. 151 ( a ) ; 14 C

. F

. R

. 9 1

. 203 ( a ) & ( b ) ; 14 C

. F

. R

. 9 1

. 405 ( a ) ; 14 C

. F

. R

. 9 1

. 407 ( a )( 1 ) ; 14 C

. F

. R

. 9 1

. 409 ( a )( 2 ) ; 14 C

. F

. R

. 9 1

. 417 ( a ) & (b)

.3 4. Statutory Authority for Exemptions

The Federal Aviation Act expressly grants the FAA authority to issue exemptions . This statutory authority includes civil aircraft as the term is defined under §40101 of the Act, including sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate.

The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if the Administrator finds the exemption in the public interest. 49 USC §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1).

Section 333(b) o f the Reform Act assists the Secret ary in determining whether sUAS may operate in th e National Airspace System (NAS) without creating a hazard to the user, the public, or pose a threat to national security. In making this determination the Secretary must consider:

• T he sUAS’s size, weight, speed, and operational capability;

• Whether the sUAS operates within visual line of sight of the operator;

• Op eration of the sUAS in close proximity to airports and populated

areas.

Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such ai rcraft in t h e national airspace system.” Id. §33 3( c).

5. Secondary Documentation (Proprietary)

The following secondary documentation is provided for reference as supplemental information pertaining to this Petition:

1. AR

- sUAS Flight Standards 2. AR

- Preflight Inspection & Operations Check List 3. AR

- 960 sUAS Manual 4. AR

- 540 sUAS Manual

These documents will be retained at the ground control point accessible by the pilot in command (PIC).

6. Unmanned Aircraft Systems

Advanced Robotics designs and pur p ose builds it s sUAS for mission specific applications utilizing commercially available airframes, flight controllers, electronics, and components. They ar e multi rotor equipped aircraft one meter in diameter or less, and less than 55 pounds in weight including payload.4 They op erate at a speed of no more than 50 knots and have the ability to hover, and move in the vertical and horizontal plane simultaneously. They are equipped with GPS Flight C ontrollers and data link communications capability for operator control via ground control station or hand radio transmitter contr ollers and have battery

- limited flight duration of less than one hour. The GPS Flight C ontr oller can be programmed to limit flight duration with auto

- land functions, and limits for flight distance and above ground level (AGL) altitude, and have return

- to

- home , loiter, and predetermined landing location functions in the event of lost data link communications or flight anomalies. Operating within visual line of sight (VLOS) of the PIC and visual

o bserver (VO) at no more than 500 feet AGL and will operate only within the areas described he rein. Such operations will e nsure that the sUAS will not create a hazard to users of the NAS or the public as described in the FMRA §333(b).

Advanced Robotics proposes within this petition the use of t wo different sUAS platforms, AR

- 960 and AR

- 540

, to support varied mission, payload configurations

, and training purposes

-- see provided supplemental Manuals for each. General s pecifications are as follows:

• AR

- 960 Hex Rotor :

Airframe: Carbon Fiber Hex Rotor

– 960mm Diameter Weight: 20 pounds (maximum with payload) Propulsion: Six 400KV Electric Motors Propellers: Carbon Fiber 14”

– 16 ” Power: 22.2 Volt, (6S) Lithium

- Polymer batteries

– Dual/Redundant Speed: 0

- 45 knots Flight Time: 4 0 minutes Autopilot: GPS Flight Controller/Autopilot Dat a Link: FCC approved 2.4 GHz Video: FCC approved 5.8 G Hz Telemetry: Voltage, Current, Altitude, GPS Lat/Long, Ground Speed

• AR

- 540 Quad Rotor:

Airframe: Composite/Aluminum Quad Rotor

– 540mm Diameter Weight: 8 pounds (maximum with payload) Propulsion: Four 740KV Electric Motors Propellers: Carbon Fiber 10”

– 12 ” Power: 14.8 Volt, (4S) Lithium

- Polymer batteries

– Dual/Redundant Speed: 0

- 45 k nots Flight Time: 3 0 minutes Autopilot: GPS Flight Controller/Autopilot Data Link: FCC approved 2.4 GHz Video: FCC approved 5.8 G Hz Telemetry: Voltage, Current, Altitude, GPS Lat/Long, Ground Speed5 Advanced Robotics maintains a maintenance log book for each sUAS that docum ents maintenance history. In addition to PIC pre

- flight inspections conducted before each flight our FAA licensed A&P personnel conduct annual aircraft inspection and maintenance checks. This includes review of system and telemetry d ata files logged from prior flights, inspection for loose or worn components, balancing of props, cleaning of motors, battery voltage and cell balancing checks, etc., and performing any needed system repair and upgrades to include software/firmware for the GPS, Flight Controller/Autopilot, Radio Transmitter, and Ground Control Station. All scheduled or unscheduled maintenance and repair actions are documented within the sUAS maintenance log book. Upon completion of any repair, modification or upgrade, the aircraft is test flown by a qualified PIC and documented within the maintenance log book prior to return to service.

7

. Operation of the Unmanned Aircraft

The PIC will be an FAA licensed airman with at least a private pilot’s certificate and third class medical. Additionally, the PIC will have a minimum of 10 hours sUAS multirotor experience of which at least 5 hours are with the specific make/model sUAS to be operated (AR

- 960, AR

- 540 ), per the Advanced Robotics sUAS Flight Standards document

.
Training of PICs who do not meet the sUAS multirotor experience will be gained within dedicated training sessions throu gh use of a multirotor computer simulator (ground training) and the sUAS platform ( s ) (logged flight time) as requested through this exemption. Upon meeting the sUAS flight hour requirements , logged in a consistent manner per 14 CFR § 61.5(b), a flight proficiency check will be conducted by a Advan ced Robotics FAA rated CFI prior to allowing a PIC to conduct flight operations. Flight currency will be maintained by the PIC having logged 30 minutes flight time within the proceeding 90 days with the specific make/model UAS platform. Regaining currency will be achieved in dedicated training/currency sessions. In addition to flight proficiency, the PIC will be trained in use of the radio control transmitter, ground control station, pre

- flight inspection of the sUAS, and operational procedures per Advanced Robotics sUAS Flight Standards document paraphrased as follows

.
Minimum crew for each flight operation will consist of the sUAS PIC and Visual Observer (VO). Flights will be conducted within VLOS of the PIC at all times with VO duties assisting PIC in maintaining VLOS and situational

aware ness of obstructions, hazards and avoiding other aircraft

. Communication between the PIC and VO will be maintained through direct voice communications and/or through use of two

- way radio or cell phone throughout the duration of flight.

Prior to each flight the PIC will conduct a thorough pre

- flight inspection , per6 the Advanced Robotics Preflight and Operations Checklist, to ensure the sUAS i s in safe condition for flight. The pre

- flight will include p hysical inspection of components, battery voltage level checks, motor run

- up, payload system, ground control station and communications checks in preparation of flight. If the inspection reve als a condition that prohibits safe operation, the PIC will remove the aircraft from service until the necessary maintenance has been performed and documented and the s UAS is found to be in a condition for safe flight

.
The PIC will conduct pre

- flight plan ning to include obtaining weather briefings, identifying hazards and obstructions, and establishing predetermined mission flight path and limited and controlled area for safe operation

. The Petitioner will submit to the Air Traffic Organization (ATO) a Ce rtificate of Waiver or Authorization (COA) prior to conducting any flight operations. The Petitioner will request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.

All flight operations will b e conducted within a limited area that is strictly controlled over private or controlled

- access property with permission from the land owner or their authorized representative for each flight to be conducted. The PIC will conduct pre

- flight safety briefin gs with all personnel supporting flight activities in regard to the planned sUAS operations and mission plan prior to each flight. Flight operations will typically be conducted at least 500 feet from all nonparticipating flight operation people, vessels, vehicles, and structures unless there are barriers or structures that safely protects nonparticipating per sons in event of accident. In the event nonparticipating persons leave such protection and are within 500 feet of the sUAS, the PIC will immediately cease flight operations

. Additionally, if owner of vessels, vehicles, or structures provides permission and the PIC determines safe operations can be conducted with undue risk to operating pers onnel then flight operations may be conducted closer than 500 feet.

Advanced Robotics will not conduct f light operations over congested or densely populated areas, or within 5 miles of an airport unless a letter of agreement is obtained from the airport management and per NOTAM. All f lights will be conducted under visual meteorological conditi ons (VMC) during daylight hours, at less than 50 knots airspeed and an altitud e no greater than 500 feet AGL, and will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibilit y is less tha n 3 statute miles from the PIC. Maximum flight time for each operational flight will be 4 0 minutes and allowing for no less than 20 % battery as indicated by real

- time telemetry voltage/current data relayed by the aircraft sensors to the PIC control station.

In event the PIC losses data link communicati ons, the GPS equipped sUAS have the capability to return to a pre

- determined location and land and7 provides the PIC capability to abort flight and initiate loiter and return

- to

- home functions. If an in

- flight emergency occurs, the PIC will immediately abort flight and initiate landing procedures.

By adhering to these operational procedures

, Advanced Robotics , will achieve a safety level equivalent to, or greater than that

, directed by the rules in which they seek exemption. sUAS are inherently safer in all facets due to the fact they are much smaller, fly at much slower speeds, have no human operators or occupants on board and no flammable fuels to be concerned of in event of crash. As sUAS processes are further refined, and commercial flight experience gained, the operations will serve to enhance an already higher level o f safety compared to manned flight operations in which serves the public’s best interest in the FAA’s pursuit to integrate UAS into the NAS.

Du e to the small size of the sUAS involved, ability of the PIC to control and set flight parameters, and the controlled and limited environment in which they will operate, the Petitioner falls squarely within that zon e of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow comm ercial operations of sUAS to commence immediately. Additionally, due to the Private Pilot rating of the PIC, the size of the sUASs, limited payload capacity and flight durations, the use of batteries versus flammable fuels, and the limited and tightly controlled areas in which the sUASs will operate, approval of the application presents no national security issue.

Given the clear direction in FRMA §333, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts due to battery operation, and reduced costs of sUAS aircraft assets as compared to conventional aircraft, the grant of the requested exemptions is in the public interest. Accordingly, Advanced Robotics respectfully requests that the FAA grant the requested exem ption without delay.

8

. Description of Specific Regulations

Pursuant to 14 C.F.R. § 11.81(e), Advanced Robotics seeks exemption from the below mentioned regulations and provides reason as to why the exemption should be approved based on the level of safety at least equal to that of which the rules require.

• 14 C.F.R. Part 21 Subpart H

– Airworthiness Certificates Ø Establishes: The procedural requirements for the issuance of airworthiness certificates as required by 14 C.F.R. § 91.203(a)(1)8 Given the small size of the s UAS, the controlled operating areas

, limitations and conditions Advanced Robotics will adhere to d uring flight operations, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the “Reform Act” with consideration “of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS.”

• 14 C.F.R. § 45.23(b)

– Aircraft Marking and Identification Requirements

Ø 14 C.F.R. § 45.23(b) , Markings of the Aircraft, states: When marks include only the Roman capital letter "N" and the registratio n number is displayed on limited, restricted or light

sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport, "experimental," or "provisional," as applicable.

The sUAS to be flown by Advanced Robotics have no airworthiness certificate, an exemption may be needed as t he sUAS have no entrance to the cabin, cockpit, or pilot station on which the word “Experimental” can be placed. The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

• 14 C.F.R. § 61.113(a) and (b): Private Pilot Privileges and Limitations: Pilot in Command

Ø Sections 61.113 (a) and (b) limit private pilots to non

commercial operations.

Because the sUAS will not carry a pilot or passengers, the proposed operations can achieve the equivalent level of safety of current operations by requiring the PIC operating the aircraft to have a private pilot’s license rather than a commercial pilot’s l icense to operate a sUAS. Unlike a conventional manned aircraft, a sUAS is remotely controlled by a ground

- based operator. The operational area is controlled and restricted, and all flights are planned and coordinated in advance. The level of safety excee ds that provided by a single individual holding a commercial pilot’s certificate operating a conventional aircraft. The risks associated with the use of a sUAS are so diminished from the level of risk associated with commercial operations contemplated by P art 61 allowing sUAS use by a private pilot as the PIC exceeds the present level of safety sought by 149 C.F.R. §61.113 (a) and (b).

• 14 C.F.R. 91.7(a)

– Civil Aircraft Airworthiness Ø No person may operate a civil aircraft unless it is in an airworthy condit ion.

There is no airworthiness certi ficate for the sUAS to be operated by Advanced Robotics . To provide an equivalent level of safety

, th e PIC will conduct pre

- flight inspections to ensure airworthiness. During flight, the PIC will adhere to § 91.7(b) and abort air operations immediate ly upon identification of an in

- flight anomaly or emergency. Licensed A&P staff will conduct annual inspections

. Maintenance l og books will be maintained fo r each sUAS thereby achieving an equivalent level of safety.

• 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft. Ø Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ..(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, un less there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

The sUAS, given their size and configuration have no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry s uch an item on the aircraft pla tform

. The equivalent level of safety will be maintained by keeping the sUAS documentation at the ground control point where the PIC will have access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10 700.

• 14 C.F.R. 91.103

– Pre

- flight Action Ø Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include

- (paragraphs a, b, 1 and 2)

The PIC will take all actions, to include flight and mission planning, reviewing weather, flight battery requirements, safe take

- off and landing areas, and aircraft performance data before commencement of flight. In addition, the PIC will verify the sUAS is ready for flight by conducting a pre

- flight inspection and run up of systems and data

- link communications checks prior to each flight.

The exemption requested for this section is specifically addressed10 toward the requirements which do not apply to sUAS operations such as runways and air traffic control integration. The airport manager will be notified and approval obtained prior to any op erations being executed less than five statute miles of an operating airport

. 14 C.F.R. §91.109: Flight instruction Ø Section 91.109 provides that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

sUAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a radio transmitter or ground control station that communicates with the air craft via a receiver in the sUAS . The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. S ee Exemption numbers 5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilo t nor passengers will be occupants in the aircraft and by the small size and slow speed of the sUAS

.

• 14 C.F.R. 91.119

– Minimum Safe Altitudes Ø 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

case s, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimu ms prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FA A. This exemption is for a sUAS and the exemption requests authority to operate at altitudes up to 500 AGL underneath navig able airspace and in class E and G airspace maint aining safe separation from manned aircraft, an exemption may be needed to allow such operations.

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the limi ted and controlled location where it is operated. Compared to flight operations with manned aircraft weighing far more than the maximum 55 pounds proposed herein, and the lack of flammable fuel, any risk associated with these operations is far less than th ose presently presented with conventional manned aircraft. In addition, the low

- altitude operations11 of the sUAS will ensure separation between it and operations of conventional manned aircraft that must comply with Section 91.119.

• 14 C.F.R. §91.121 Altimet er Settings Ø 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 do not have a n adjustable barometric altimeter an exemption is required. An equivalent level of safety will be achieved by the PIC , confirming the altitude of the launch site via the sUAS GPS

.

• 14 C.F.R. 91.151(a)

– Fuel Requirements for Flight in VFR Conditions Ø 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

— (1) During the day, to fly after that for at least 30 minutes;

This regulation is written based on the capabilities of a traditional aircraft which have flight times of several hours or greater; therefore, with the majority of sUAS which have flight times of only an hour or less, this regulation would effectively deny the ability of the air vehicle to operate.

To meet the intent, Advanced Robotics , will limit its sUAS flights to 40 minutes, or no less than 20% remaining battery power, which ever occurs first, to e nsure safe landing an d retrieval of the air vehicle and providing at least an equal level of safety. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

• 14 C.F.R. §91.203 (a) and (b): Carrying Civi l Aircraft Certification and Registration Ø The regulation provides in pertinent part:

(a) Except as provided in§ 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate..

.. (b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to12 passe ngers or crew.

The sUAS fully loaded weighs no more than 55 lb s. a nd is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration docum ents or to display them on the sUAS

. An equivalent level of safety will be achieved by keeping these documents at the ground control point where the PIC will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation . A representative sample of other e xceptions includes Exemption numbers 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

• 14 C.F.R. 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) & (b)

– Maintenance Inspections Ø 91.405(a) States: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter

.

Ø 91.407(a)(1) States: (a) No person may operate any aircraft that has 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

.

Ø 91.409(a)(2) States: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

— (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an ‘‘annual’’ inspection in the required maintenance records.

Ø 91.417(a) & (b) States: (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 peri ods specified in paragraph (b) of this section: (paragraphs 1 (i

– iii), 2 (i

– vi)); (b) The owner or operator shall retain the following records for the periods prescribed: (paragraphs 1

– 3)

Pre

- flight inspections and routine maintenance will be accomp lished by the PIC to ensure the sUAS is in good working order prior to flight . If mechanical issues or emergency situations arise the sUAS can land13 immediately and given its small size poses very little risk to persons or property. Upon completion of any repair, modification or upgrade, the aircraft is test flown by a qualified PIC and documented within the

ma intenance log book prior to return to service. Annual inspection s and maintenance will be conducted and documented within the sUAS maintenance log b ook by licensed A&P personnel to meet t he intent of these regulations and provide an equivalent level of safety.

9

. Summary the FAA may publish in the Federal Register

Advanced Roboti cs see ks an exemption from the following Regulations: 14 C.F.R. Part 21; 14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103; 91.109; 91.119; 91.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a ) (1); 91.409(a ) (2); 91.417(a)&(b ) to commercially operate its small unmanned aircraft systems to support a variety of industry and business applications, to include, but not limited to, Education and Training, A erial Survey/Inspection and Imaging, Ranch and Agricultural, Forestry, Wildlife Preservation, Law Enforcement, and Search and Rescue. Granting Advanced Roboti cs request fo r exemption will reduce current ri sk level s and thereby enhance safety.

Further, Advanced Robotics sUAS operates at lower altitudes , up to 500 feet AGL, in predetermined and controlled airspace

, weigh ing less than 55 pounds and traveling at speeds l ess than 50 knots. They will provide at least an equivalent level of safety as that achieved under current FARs.

Advanced Robotics respectfully requests that the FAA grant its exemption request without delay. The FAA has t he authority to issue the exemption sought by A dvanced Robotics pursuant to the Federal Aviation Act, 85 P.L. 726 (1958), as amended (the "Act").

By__________________________ for: Advanced Robotics David M. Garrett 5901 E. Lippizan Way Hereford, AZ 85615

Tel: 520.227.1865 david.garrett@msn.com