September 17, 2015

Exemption No. 12902 Regulatory Docket No. FAA

− 20 15

− 2686

Mr. Alejandro Araya dba AA FLYDRONESFL LLC 5900 NE 2 Terr ace Oakland Park, FL 33334

Dear Mr. Araya :
This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

By letter dated June 1, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of Mr. Alejandro Araya dba AA FLYDRONESFL LLC ( hereinafter petitioner or
oper ator ) for an exemption . The petitioner requested to operate an unmanned ai rcraft system (UAS) to conduct photography, surveying, and videography for real estate, construction, and utility inspections

. See Appendix A for the petition submitted to the FAA des cribing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

.

Airworthiness Certification

The UAS proposed by the petitioner is a 3D Robotics Solo

.2

The petitioner requested relief from 14 CFR part 21, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates

. In accordance with the statutory criteria provided in Section 333 of P ublic Law 112

− 95 in reference to 49 U

. S

. C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA fi nds that the requested relief from 14 CFR part 21

, C ertification procedures for products and parts, Subpart H

— Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is
not necessary.

The Basis for Our Decis ion

You have requested to use a UAS for aerial data collection 1

. The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption No s

. 11062 to Astraeus Aerial ( see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Lab s , Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11 062, 11109, 11112, and 11213 ;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Mr. Alejandro Araya dba AA FLYDRONES FL LLC is granted an exemption from 14 CFR §§ 61.23(a) and ( c ), 61.101(e)(4 ) and (5), 61.113(a), 61.315(a) , 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (part iculate measurement, etc.), or any other gathering of data by instruments aboard the UA.3

perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Alejandro Araya dba AA FLYDRONESFL LLC is hereafter referred to as the operator.

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of exempt ion are limited to the 3DRobotics Solo when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption

.

2. Operations for the purpose of closed

- set motion pictu re and television filming are
not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) 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 ai rman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement as l ong as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times ;

e lectronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfe r his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required of the VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions an d limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating4

documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists betwee n the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its op erating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator or any law enforcement official upon request. The
op erator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FA A’s UAS Integration Office (AFS− 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterat ions that affect the UAS operation or flight characteristics, e.g.

, replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducte d by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. The pre

- flight inspection must account for all potential discrepan cies, e.g.

, inoperable components, items, or equipment. 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.

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply wi th all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Col u mbia, Puerto Rico, a territory, a possession, or the Federal5

government. The PIC must also meet the flight revi ew requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and em ergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the ope rator’s PICs and VOs (traini ng, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During traini ng, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operat e the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flig hts under special visual flight rules (SVFR) are not authorized.

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbo l as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with t he airport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS sign al, the UA must return to a
pre

- determined location within the pr ivate or controlled

- access property.

19. The PIC must abort the flight in the event of unpredicted obstacles or emergen cies.

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the rese rve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be cond ucted in accordance with an ATO

- issued COA. The6

exemption holder may apply for a new or amende d COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

.

22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have ide ntification (N− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 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 Administrator or any law enforcement official upon request.

24. The UA must remain clear a nd give way to all manned aviation operations and activities at all times.

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

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, v ehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protectio n. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator t rainees or essential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over private or control led

- access property with permission from the property owner/controller or authorized representative. P ermission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FA A's UAS Integration Office (AFS− 80) within 24 hours. Accidents must be7

reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose of closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the a rea of proposed filming. 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 flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of th e person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N− Number of UAS to be used;

e. Name and certificate number of UAS PICs invol ved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production 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 of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operati on.

31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption , the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on September 30, 2017 , unless sooner superseded or rescinded.

Sincerely, / s/ John S. Duncan Director, Flight Standards Service

Enclosures**1**

**June 1, 2015**

**U.S. Department of Transportation Docket Management Sy**  **stem 1200 New Jersey** 

**A ve., SE**  **Washington, DC 20590**

**Re: Exemption Request under Section 333 of the FAA Reform A**  **ct and Part 11 of the**  **Federal I A**  **viation Regulations**

**Dear Sir or Madam:**

**Pursuant to Section 333 of the FAA Modernization and Reform A**  **ct of 2012 (the "Reform A**  **ct") and 14 C.F.R. Part 11, A lejandro A**  **ray a dba**  **AA FLYDRONESFL.llc,**  **the operator of small Unmanned A ircraft Systems ("sUA**  **S"), seeks an exemption from the Federal A** 

**viation Regulations ("FA**  **Rs") listed below and discussed in Ap**  **pendix A.**  **A**

**ttached as A ppendix B is a summary**  **of this request.**

The requested exemption would permit commercial operation of Alejandro Araya **dba AA**  **FLYD R**  **ONESFL sUA S's, w**  **hich weigh approximately 10 l**  **bs. An**  **d performs**  **aerial survey s and videography**  **that consists of still photographs and videograph**  **y taken by on board cameras. The sUA**  **S's takes a series of high quality**  **, still digital images and video that are used to promote real estate sales and survey in Sou**  **th Florida. A dditional aerial inspections/survey**  **applications**
**may include construction jobsite monitoring, pipeline inspection and precision**  **topological survey s. Use of the sUA**  **S for aerial inspections and surveys reduce the need to utilize conventional man**  **ned aircraft, manned lifting devices or manned climbing for the same purpose and provides very high quality**  **imagery**

**at a fraction of the cost. These savings result in enhanced safety**  **, efficiency and**  **productivity for the affected activities, as well as envi ronmental benefits.** 

**Operations under the exemption will be subject to strict operating requirements and conditions to ensure at least an equivalent level of safety**  **to currently authorized operations using manned aircraft and under conditions as may**  **be mod**  **ified by**

**the FAA**

**as required by**

**Section 333.**

**As described more fully**  **below , the requested exemption would authorize**  **commercial operations of aerial photos and inspections or surve ys**  **using the sUA**  **S's, w hich weigh less than**  **10 lbs. and are small in size. (S**  **ee attached O&M 2** 

**manuals for the 3DR SOLO ). The sUA**  **S's will be operated under controlled conditions at low altitude in airspace that is limited in**  **scope, as described more fully**  **herein; it will have automated control features as described below and in the O**  **&M manuals. The sUA S also will be operated by**  **an individual who has FAA**  **Priv ate Pilot License. Finally**  **, the airspace in which the sUA**  **S will operate will be Class G airspace or airspace approved by the FAA**  **in advance.** 

**Al ejandro**  **Ar ay**  **a dba**  **AA FLYDRONESFL**  **res pectfully**  **submits that because these small, unmanned aerial**  **vehicles will be used in lieu of comparatively hazardous operations now conducted with fixed**  **wing and rotary conventional aircraft or**  **other manned means of inspections, the FAA can hav**  **e confidence**  **that the operations will achieve at least the equivalent level or greater level of**  **safety**

**. Ap**  **proval of the exemptions w ould thereby enhance safety**  **and fulfill the Secretary** 

**of Transportation's (the FAA**  **A dministrator's) responsibilities under**  **Section 333( c) of the Reform**  **Ac t to "establish requirements for the safe operation**  **of such aircraft sy stems in the national**  **airspace sy stem."** 

**The name and address of the applicant are:**

**Al ejandro**  **Ar ay**  **a dba**  **AA FLYDRONESFL**  **Att: Al**  **ejandro Ar**  **ay a**  **Ph: 954** 

**- 661** 

**- 7469**  **Email: alexawl@bellsouth.net**  **Ad dress:**  **5900 NE 2 Terr**

**Oakland Park,**  **FL 33334** 

**The regulations from which the exemption is requested are as follows: 14 C.F.R. Part 21;**  **14 C.F.R. 45.23(b); 14 C.F.R. 61.113(a) & (b);**  **14 C.F.R. 61.133 (a); 14 C.F.R. 91.7(b);**  **1 4 C.F.R. 91.9(b)(2);**  **14C.F.R. 91.109(a); 14 C.F.R. 91.119;**  **14 C.F.R. 91.121; 14 C.F.R. 91.151(a);**  **14 C.F.R. 91.203(a) & (b); 14 C.F.R. 91.405(a);** **3**

**14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(2};**  **14 C.F.R. 91.417(a) & (b).**

**Ap pendix**  **A discusses each rule lis**  **ted above and explains why exemptions**  **pursuant to the proposal set forth in this letter are appropriate, provide an**  **equivalent level of safety, and are in the public interest.** 

**The A pplicable Legal Standard under Section 333** 

**Al ejandro**  **Ar ay**  **a dba**  **AA FLYDRONESFL**  **submits that grant of this exemption application for use of the**  **proposed UA S's in precision aerial inspections will**  **advance the Congressional mandate in Section 333 of the Reform A**  **ct to accelerate the introduction of UA**  **Ss into the national airs pace**  **sy stem ("NA**  **S") if it can be accomplished safely**  **. This law directs the Secretary of**  **Transportation to consider whether certain UA**  **Ss may operate safely** 

**in the NA S before**  **completion of the rulemaking required under the Section 332 of the Reform A**  **ct. In m aking**  **this determination, the Secretary**  **is required to determine which types of UA Ss do**  **not create a hazard to users of the NA**  **S or the public or pose a threat to national security**  **in the light of the follow**  **ing:**

• **The UA S's size,**  **weight, speed and operationa l capability**  **;**

• **Operation of the sUA S in closed proximity to airports and populated**  **areas; and**

• **Operation of the UA S**  **within visual line of sight of the operator.**

**Reform A ct §333{a)(1). If the Secretary**  **determines that such vehicles "may operate saf**  **ely**

**in the national airspace sy**  **stem, the Secretary shall establish**  **requirement for the safe operation of such aircraft in the national airspace** 
**sy stem.**  **" ld. §333(c) (emphasis added).**

**The Federal A**

**viation A ct expressly** 

**grants the FAA**

**the authority to iss ue**  **exemptions. This statutory authority**  **, by its terms, includes exempting civil**  **aircraft, as the term is defined under §40101 of the A**  **ct, from the requirement that all civil aircraft must have a current airworthiness**  **certificate and those regulations requi**  **ring commercial pilots to operate aircraft in commercial service:** 

**The A dministrator may**  **grant an exemption from. a requirement of a regulation 4** 

**prescribed under subsection (a) or (b) of this section or any of the sections**  **44702**

**- 44716**  **of this title if the A dministrator finds the exemption is in the public**  **interest.**

**Ap plicant submits that this provision places a duty**  **on the A dministrator to not**  **only process**  **applications for exemptions under Section 333, but for the Ad**  **ministrator, if he deems the conditions p**  **roposed herein require modification in order to allow approval, to supply**  **conditions for the safe operation of UA S. Todd**  **Thomas dba Drone Pies welcomes the opportunity to consult with FAA**  **staff in order to address any** 

**issues or concerns that this proposal**  **may raise that they believe may** 

**require modification. 49 U.S.C. §44701(f). See also 49 U.S.C. §44711 (a); 49 U.S.C. §44704; 14 C.F.R.**  **§91.203(a)(1).**

**The grant of the requested exemption is in the public interest based on the clear direction in**  **Section 333 of the Reform A**  **ct; the additional authority in the Federal**  **Aviation Ac**  **t, as amended; the strong equivalent level of safety**  **surrounding the proposed operations; and the**  **significant public benefit, including enhanced safety**  **and cost savings associated w ith**  **transitioning to UA Ss for aerial**  **inspections and survey photography and real estate**  **photography . A**  **ccordingly, the applicant respectfully**  **requests that the FAA grant the requested**  **exemption without delay**

**.**

**Ai rw**  **orthiness of the sUA S** 

**A critical element**  **of the exemption application involves evidence of the airworthiness**  **of the sUA**  **S. The Federal Aviation Ac**  **t (49 U.S. C. §44701 (f) and Section 333 of the Reform A**  **ct both authorize the FAA**  **to exempt aircraft from the requirement for an airw**  **orthiness certific ate,**  **upon consideration of the size, weight, speed, operational capability**  **, and proximity to airports**  **and populated areas of the particular sUA**  **S. Our small UAS's will operate at low speed in a controlled environment, at least five miles from an airport or**  **densely populated**  **area. A n**  **analy sis of these criteria demonstrates that the UA**  **S operated without an airworthiness**  **certificate, in the restricted environment and under the conditions proposed will be a least as**  **safe, or safer, than a conventional aircraft (fixed wing**  **or helicopter) operating w ith an**  **air worthiness certificate without the restrictions**  **and conditions proposed.**

**Mandatory**

**Operating Conditions (see O&M and Safety lists)** **5**

**Grant of the exemption to Al**  **ej andro A**  **ra ya**  **dba AA FLY DRONESFL**  **will be subject to the follow**  **ing mandatory**  **conditions, which are based upon operating conditions set forth for operation of**  **sUA S by**  **public entities pursuant to Certificates of A**  **uthorization, with additional restrictions:**

• **Al l operations to occur in Class**  **G airspace.**

• **Operations to avoid congested or populated areas, which are depicted in y**  **ellow on VFR**  **charts.**

• **Operations to be conducted over private or controlled**

**- access property** 

**.**

• **Permission from land ow ner/controller required before commencing**  **flight.**

• **Operat ions to occur during Visual Flight Rules Meteorological**  **Conditions (VMC).**

• **Ai rcraft to remain within Visual Line of Sight (VLOS).**  **V LOS guaranteed with**  **a cy linder**  **of operation around operator of 1⁄2**  **nautical miles**  **(NM).**
**Cy linder walls may** 

**be expanded by**

**obse rver w**  **ith ability**

**to control aircraft.** 

• **Operations to occur during day light hours.** 

• **Ab ove Ground Level (A**  **GL) altitude to be restricted to 400 feet.**

• **Al l operations conducted in vicinity**  **of airport to remain more than 2.5 NM from** 

• **centerline azimuth of runway c**  **enterline measured from runway thresholds** 

• **Al l required permissions and permits will be obtained from territorial,**  **state, county**

**or city**  **jurisdictions, including local law enforcement, fire, or other appropriate**  **gov ernmental agencies.** 

**Operator Requiremen ts** 

**Al ejandro**  **Ar ay**  **a dba**  **AA FLYDRONESFL**  **respectfully purposes that operator**  **requirements should take into account the characteristics of the particular UA**  **S. Certain UA**  **Ss, such as the 3DR SOLO**  **are characterized by a high degree of**  **control and various built**

**- i**  **n technical capabilities that limit the potential for**  **operation outside of the operating conditions set forth above. Please see details**  **in the attached O&M manuals.**

**Ad ditional automated safety**  **functions and safety enhancing features of the**  **sUA S's include**  **the following:** **6**

• **Au to** 

**- pilot detection of lost GPS or of insufficient satellites initiates an**  **immediate return to aircraft take** 

**- off location ("home").** 

• **Low power on the aircraft triggers escalating alarms at GCS.** 

• **If the auto**

**- pilot detects a lost** 

**- link to the**  **GCS, landing procedure begins.**

• **Pause Button**

• **The Pause button/Panic, will freeze Solo mid**

**- air and hover until given**  **another command. This can be useful to stop Solo from hitting an obstacle or to re** 

**- orient Solo for navigation** 

**Given these safety**

**features, A**  **lejandro Ar**  **ay a**  **dba AA**  **FLYDRONESFL proposes**  **that operators of the sUA S**  **shou l**  **d not be required to hold a commercial pilot certification. Instead, operators should be**  **required to:**

• **Hold a private pilot license**

**.**

• **Have completed the manufacturer's training**  **program for operation of**  **the sUA S's.** 

**Al ejandro**  **Ar ay**  **a dba**  **AA FLYDRONESFL**  **notes that the FAA has found that safety**  **factors permitted operation of sUA**  **Ss by operators with these qualifications in the**  **case of operations pursuant to public COA**  **s wh**  **en the mandato ry**  **operating conditions specified above were present. See**  **Federal A viation A**  **dministration, Notice N** 

**- 8900.227, Unmanned A**  **ircraft Systems (UA S)**  **Operational A pproval, at**  **20**

**- 21 (July** 

**30, 2013). The FAA**

**has the statutory authority to grant**  **exemptions to the req**  **uirements for and privileges associated with the grant of airmen's certificates. 49 USC §44701 (f).**  *** * *** **In summary , applicant seeks an exemption from the FA**  **Rs set forth above in Ap**  **pendix A**  **to allow commercial operations of a sUA**  **S's conducting precision**

**a erial inspections or surveys and**  **real estate photos.**

**Ap proval of the exemption allowing commercial operations of the sUA**  **S for precision**  **inspection, survey**  **wo rk, and real estate photos will enhance safety**  **by reducing risk.**  **Conventional aerial inspection, survey operations, and real estate**  **photos, using jet or piston powered**  **aircraft present risks associated with vehicles that weigh in the neighborhood of 5,000**  **to 7,000 lbs., or more, carry large quantities of fuel, passengers, and, in some cases, cargo.**  **S uch aircraft**  **must fly to and from the survey location. Other conventional manned climbing or**  **manned lifts risk safety hazards associated with falls, electrical hazards, fuel related hazards,**  **and inhalation associated with the structures being inspected. In contrast, a sUA**  **S weighing less than 15 lbs. and powered by**  **batteries eliminates a 7** 

**portion of that risk given the reduced mass and lack of combustible fuel carried**  **on board a manned aircraft and the lack of risks associated wit**  **h manned lifts or manned clim**  **bing apparatus. The sUA S will carry**  **no passengers or crew and, therefore; will not expose any**  **individuals to the risks associated with manned aircraft**  **flights, manned lifts or climbing hazards.**

**Ad ditionally, no national security**  **issue is raised by**

**the g rant of the requested**  **exemptions. Given the size, load carry**  **ing capacity , speed at which it operates,**  **and the fact that it carries no explosives or other dangerous materials, the sUA**  **S poses no threat to national security** 

**.**
**The operation of the sUA S,**  **weighing less than 15 lbs ., for inspections, surveys, and real estate**  **photos in accordance with the strict conditions outlined above, will provide an equivalent level**  **of safety supporting the grant of the exemptions**  **requested herein, including exempting A**  **lejandro Ar**  **ay a**  **dba AA**  **FLY DRONESFL from the requirements of Part 21.** 

**The sUA S's satisfaction of the criteria set forth in Section 333 of**  **the Reform A ct** 

**** **size, weight,**  **speed, operating capabilities, lack of proximity to airports and**  **populated areas, operati on**  **within visual line of sight, and national security**

**- and**  **it’s showing of an equivalent level of safety**  **as it may relate to the requirement for**  **FAA training, provide more than adequate justification**  **for the grant of the requested exemptions allo**  **wing commer cial operation of the sUA**  **S in the commercial aerial inspection, survey**  **, and real estate photo business.**

**Very truly**  **yours,**

**Al ejandro**  **Ar ay**  **a Ow**  **ner AA**  **FLYDRONESFL Enclosures:** 

**Ap pendix**  **A: Exemption Request and Equivalent Level of Safety Showings under**  **Ap plicable Rules Subject to Exemption**  **Ap pendix B: Operation and Maintenance Manuals:**  **3DR SOLO Manual**  **Ap pendix C: Safety** 

**Checklists**