December 25'd 2015

US Department ofTransportation Docket Management System 1200 New Jersey Avenue Southeast Washington DC 20590 ': l 1.;.. )
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Re: Request for Exemption under Section 333 ofthe FAA Modernization and Reform Act of2012 and Part 11 ofthe Federal Aviation Regulations.

Name and address of Petitioner Scott Donahue - RVC Air Studios 5124 Yuma Lane North

'Plymouth, Minnesota 55446 Phone number 612-867-7752 Email:·donzi121256@gmail

.com

Dear Sir or Madam :**Pursu~ntto se** **c~ion 33~**  ofthe FAA Modernization and Reform ·Act of2012 and 14 CFR part 11, Kris Donahue-RVC Air Studios the petitioner, request exemption from the following Federal Aviation Regulations in order to legally operate an unmanned aircraft system UAS in the National Airspace system. Regulations from which the Exemption is requested 14 CFR 21 H, 14CFR 45

.23 B, 14 CFR 61.113 A&B, 14 CFR 91

.7 A, 14 CFR 9L9 D2, 14 CFR 91.10 3D, 14 CFR

.91.109, 14·CFR 91:119, 14 CFR 91

.121, 14 CFR 91.151 A1-14 CFR 91.203 A & B, 14 CFR 91.405 A, 14 CFR 91.407 A 1, 14 CFR 91.409 A & B, 14 CFR 91.417 A & B, 14 CFR Title 14 Chapter 1 Sub D part 62 thru 67- 6L1 to 61.429. Petitioner wishes to be granted the Exemptions ofthe UAS Commercial Operations listed below Applications and Operations State and Municipal Roadways for Planning, New Construction, Re-construction and Repair Bridge Abutments, Column Placements and Job Site Access RoutesTopographical Overhead ofConstruction site Environmental Assessments Location of Utilities, Wetlands and other unforeseen obstacles for Road Construction Aerial photography real time Day-to-Day progress Identify potential Ground Construction Safety concerns Producer's Plants and Gravel Pits Mapping and Monitoring Stockpile quantities Aerial Photography to ensure Waste Water Runoff is in compliance with all Local Regulations Equipment Inspections Visual Monitoring of Equipment and placement Operations: The UAS will not be operated at a speed exceeding 30knts

. (35 mph),at a attitude ofgreaterthan 400 feet above ground level, or, when visibility is less than 3 statute miles, less than 500 feet or2000 feet horizontally from a cloud

. All operations will be conducted during daylight hours under visual meteorological conditions

. The Petitioner will insure priorto operation that the PIC (Pilot in Charge) has demonstrated the ability to safely operate the SAS in a manner consistent with howthe UAS will be operated underthis exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. The Petitioner, at all times will have aVisual Observer 

### "VO" on site and in close proximity to the Pilot in Charge " PIC" during Flight operations

. The petitioner believes that the use ofthe UAS is more economical and safer to use forthe aforementioned purpose. Use ofthe UAS rather than demand aircraft is more economical to the consumer, and beneficial to the general public due to a small size, low noise and minimal impact to people and the environment

. Characteristics ofAircraft: UAS Registration #FA3Y7HNFE9 (Align 690L Hexacopter) The UAS is to be used by the petitioner is the Align 690L Hexacopter. Features Include: Autopilot System (APS M)- The APS M Control Unit has superior performance due to it cutting edge information technologies, utilizing high precision sensors and modern system control subroutines

. Dual Satellite GPS System: System is able to acquire up to 35 Satellites for maintaining positioning and assuring pinpoint accuracy for "Return to Home" feature. 3 Flight Modes: Attitude GPS, GPS Speed, GPS Angular

. (NO MANUAL FLIGHT MODE) 3 Intelligent Flight Modes: CFO Mode N/A, HCL Mode, is the Coarse Heading Lock and the POl Mode, is the " Point of Interest"

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# --Return to Home: Is activated by a remote switch on the ground station unit, or ifsignal is lost between the UAV and Ground Station the UAV will go into Failsafe and "Return to Home" automatically. Low Voltage Failsafe: Ifthe Flight Batteries drop below a specified value (Values determined by Manufacture) the UAV will enterthe Failsafe Mode and automatically "Return to Home". On Screen Display: Provides real time flight data to the Ground Station (OSD), forAltitude, Speed, Direction, Satellites Acquired, Battery Voltage, Horizon Orientation, and Distance to Home as well as Elapsed Flight Time forthat specific flight. RoHS Certified
Request for Exemption, Section 333 ofthe FAA Reform Act pertaining to Federal Aviation Regulations The petitioner request an exemption from the following regulations as well as additional regulations that made technically applied to the operation ofthe UAS

. 14 CFR 21 H Airworthiness Certificates Certification procedures for products and parts Reason for Exemption It has been determined that similar UAS do not require an air worthiness certificate has granted an exemption number 11623, 11650, 11664 and 11734. 14CFR 45.23 B Marking ofthe Aircraft These regulations provide that each aircraft must display in and the aircraft registration number in the letters at least 3 inches high. Additionally, the aircraft must display the word experimental in letters at least 2 inches high near the entrance to the cabin, cockpit or pilot station. The reason for Exception Even though the UAS will have no airthe worthiness certificate, an exemption may be needed as the UAS will not have an entrance to the cabin, cockpit or pilot station on which the word experimental can be placed given the size ofthe UAS, 2 inch lettering will be impossible

.The word experimental will be placed on the fuselage and compliance with 45.29 The FAA has issued the following exemptions to this regulation to exemption numbers 10700, 10167 8 738 and 10167. 14 CFR 61.113 a b Private Pilot Privileges and Limitations The regulation provides that no person may serve as a required pilot flight crew member ofa civil aircraft ofthe United States unless that person 1.) has a pilot certificate or special purpose authorization issued underthis part in that person's physical possession or readily accessible, 2

.) the flight is only incidental to that business or employment. 3.) the aircraft is not carry passengers or propertyfor compensation or hire.Reason for Exception The petitioner will follow all manufacturers training program and safety manuals I also please these requirements are unnecessary for a pilot controlled Drone flight additionally, current FAA proposals have committed this as afuture requirements for small UAS

. 14 CFR 91.7 A Civil Aircraft Airworthiness Civil aircraft airworthiness A no person that operate as civilized craft unless it is an air worthy condition. Reason for Exception It has been determined that similar UASs do not require airworthiness certificate, howeverthe petitionerwill ensure airworthiness through the combined use ofthe manufacturer's operation manuals and pre-flight checks

. 14 CFR 91.9 B Civil Aircraft Flight Manual in the Aircraft This regulation provides that no person shall operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent ofthis requirement is to ensure thatthe flight manual information is available to the other crew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation; the documentation would not be available to the crew. Reason for Exception The equivalent level ofsafety will be maintained by keeping flight manuals at the ground station point where the pilot flying the UAS will have immediate access to it, the FSS has issued the following exemptions to this regulation; exemption number 8607, 8737, 8738, 9299, 9299A to list afew. 14 CFR 91.1 03 B Preflight Inspection This regulation requires each Pilot in Command {PIC) to take certain actions before flight to ensure the safety offlight. As FAA approved rotorcraft flight manuals will not be provided forthe aircraft an exemption will be needed. The petitionerwill take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiating flight

. 14 CRS 91.109 Flight Instructions This regulation provides that no person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual control. Reason for Exception UAS and remotely piloted aircraft, by their design so not to have fully functional dual control. Flight control is accomplished through the use ofa control box which communicates with the aircraft via Radio Communications

.The FAA has approved exemptions forflight training without fully functional dual controls for a number of aircraft and for Flight instruction in experimental aircraft. See exemptions# 5778K and 9862A. The equivalent level ofsafety provided, by the fact that either a Pilot or a passenger will be carried in the aircraft and by the size and speed ofthe aircraft.14 CFR 91.11-9 Minimum Safe Altitudes The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the aircraft will be operating at a maximum of 400 feet AGL, we cannot comply with this requirement. Reason for Exception The use ofthe UAS will be flying no higherthan 400 feet AGL in LOS over developed and developing residential areas that may be considered congested areas.That will not always be the case and providing a property survey flight because they could be conducting over empty lots or acreage with no structure
. In the case offlying over or near existing private property while providing aerial imagery, property inspections, and property assessments, land owners will be notified in person by the petitioner, or buy a card left behind by the petitioner if requested. Petitioner will review the landowners associated risks to people and property due to the small size ofthe UAS the associated with two persons, vessels, vehicles in structures is not comparable to an aircraft and should be taken into consideration

. 14CFR 91.121 Altimeter Settings This section requires that each person operating an aircraft shall maintain the cruising altitude orflight level ofaircraft, as the case maybe, by reference to an altimeterthat is set, when operating below 18,000 feet MSL. Reason for Exception Most UAS do not have a barometric altimeter if it does have GPS that will calculate altitude, speed and position

.The petitionerwill limit flights to a maximum altitude of400 feet AGL as granted and exemption number 11623, 11624 and 11734. 14 CFR 9 0.151 A Fuel Requirements for Flight and VFR Conditions Fuel requ irements forflight in VFR condition A) no person maybe began aflight in an airplane under VFR conditions unless there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

. 1) During the day, to fly afterthat for at least 30 minutes

. Reason for Exception The UAS provides low battery warning to indicate when you should return the UAS to the launch point

. In addition a low and critical battery level warning and implemented a " Return to Home" action in these situations

.The petitionerwill not initiate aflight unless there is enough powerto fly at normal cruising speed to the intended landing point and all flights will be conducted during daylight hours and at times not to be a nuisance to others

. 14 CFR 91.203 A & BCarrying Civil Aircraft Certification and Registration This regulation provides as follows No person may operate the Civil Aircraft unless it as the appropriate and current Airworthiness Certificate

.No person may operate a Civil Aircraft unless aAirworthiness Certificate required by paragraph( A) of this section or a special flight authorization is issued under 19.71 displayed at the cabin orcockpit entrance so that it is legible passengers or crew. Reason for Exception To obtain equivalent level ofsafety and meet the intent of91.203, documentation will be housed at a ground control points where the PIC is flying the UAS for immediate access to the extent they are applicable to the UAS. And doing some research the FAA has issued numerous exemptions to this regulation. 14 CFR 91.405 A: Maintenance inspections Each owner or operator ofan aircraft A)shall have that Aircraft inspected as prescribed and Sub PartE of this part in shall be between required inspection, except as provided in paragraph Cofthis section, have discrepancies repaired as prescribed and part 43 ofthis chapter. Reasons for Exception The Petitioner shall inspect the Aircraft prior to every flight. The Petitioner also will follow the manufacturer's recommended preflight checklist and make any repairs necessary before flights occur. The Petitionerwill also maintain a log ofany maintenance and or repairs preformed. 14 CFR 91.407 (A}(1}Maintenance Operation after maintenance, preventive maintenance rebuilding or alteration A) no person may operate an aircraft that has undergone maintenance, preventive maintenance, rebuilding or alteration unless: 1) it has been approved for return to service by a person authorized under43.7 this chapter

. Reason for Exception The petitionerwho has the responsibility for the operation and safety ofthe UAS will follow the manufacturer's suggested replacement parts.

14CFR 91.409 (a) 1&2. Inspections Inspection A) except as provided in paragraph Cofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had (1) annual inspection in accordance with part 43 ofthis chapter and has been approved for return to service by a person authorized by 43.7 of this chapter or2) and exception for the issuance ofan Airworthiness Certificate in accordance with the Part 21 ofthis chapter

. No inspection performed under paragraph Bofthe 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. Reason for Exemption The Petitioner will follow manufactures suggestions to insure thatthe UAS is in condition for safe Flight at all times.14 CFR 91.417 A 

### &8: Maintenance Records Except for work performed in accordance with 91.411 and 91.413 each registered owner or operator shall keep the following records for the periods specified in paragraph Bofthis section 1 2 & 3

. Reason for Exception The Petitioner will keep a record ofall repairs and modifications

.The Petitioner also proclaims to use approved manufactured parts for all repairs and modifications. 14 CFR Title 14 Chapter 1 Subchapters D Parts 60 thru 67-61.1 to 61.429: Pilot Certification This section pertains to flight rules, pilot certification requirements, manuals, etc
. Reason for Exception Petitioner believes that these requirements are unnecessary for pilot controlled drone flights and current FSS proposals have admitted this as afuture requirement for a small UAS. In conclusion: I Scott Donahue-RVC Air Studios, the petitioner request for exemption from the above-mentioned Federal Aviation regulation in order to legally operate an unmanned aircraft system UAS and the national air space system in order to perform the applications and operations pertaining to my current construction work in asafe and controlled environment the petitioner hopes for atimely consideration, as I have made considerable investment in time and finances on this project.

# ~ Scott E

. Donahue-RVC Air Studios 5124 Yuma Lane North Plymouth, MN 55446 612-867-7752 scottd@rvcairstudios.com donzi121256@gmail.com