Soaring Eagle Imaging, LLC. 1 Exemption from Section 333

Soaring Eagle Imaging, LLC Manager: Wi lliam

Paden 133 Glen Arbor Court Brandon, MS 39042 soaringeagleimaging@yahoo.com

To Wh om It May Concern:
Soaring Eagle Imaging, LLC ( its Operating Manager Wi lliam Paden) is requesting an exemption from the requirements of 14 C.F .R §§ 6 1.23(a), 61.1 13(a) & (b), 61.195 (b)(1)(2), 91.7(a), 14 CFR Section 21 Subpart H, 91.109, 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1)(2), and 91.417(a)(b) , to operate an Unmanned Aircraft System pursuant to Section 333 of the F AA Modernization and Reform Act of 2012 (FMRA). This exemption will permit SEI, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of aerial acquisition and research in support of Government entities, agriculture indus try , utility com

panies, private and government infrastructure, scientific studies, wildlife monitoring, mining, surveying, real estate, aerial photography

, training for UAS operators, and forestry

. SEI, LLC intends to operate the DJI PHANT OM 2+, DJI INSPI RE 1, AURORA FLIGHTSCIENCES SKA TE, and AEYRON SKYRANGER AND SCOUT

. Con sideration of the speed, weight, size, and limited operating area associated with the

unm anned aircraft and its operation are all factors to be considered for this exemption. All of th e Systems Soaring Eagle Imaging, LLC will be operated and maintained within the guidelines of the respected manufacturer recommendations. The DJI Phantom 2+ and DJI Inspire 1 are vertical takeoff and landing (VT OL) Unm anned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronicSoaring Eagle Imaging, LLC. 2 Exemption from Section 333

tablet or smart phone systems. The DJI Phantom 2+ has a maximum gross weight of approximately 2 pounds 1 1 ounces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of appr oxim ately 29 knots. The DJI Inspire 1 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 1 1.8 inches, and a maximum speed of approximately 42 knots. The DJI Phantom 2 and DJI Inspire 1UAs are equippe d with four main rotors; driven by Lithium Polymer battery powered electric motors. The Aurora Flight Sciences Skate is a VTOL winged UA

V that is controlled with a ground station, weighing approximately 2.7 pounds operational. It is approximately 19 inche s long by 24 inches wide and is capable of approximately 5

- 50 knots. The Aeyron SkyRanger is a four bladed VTOL system weighing approximately 5.3 lbs

. operational with a diameter of 40 inches deployed. It sits 9.3 inches high. It is controlled by a fully integrated Ground Station. The Aeyron Scout is a smaller four bladed VTOL weighing approximately 3 pounds, 28 inch diam eter deployed, and 8.5 inches high. It is controlled using a full y integrated ground station.Soaring Eagle Imaging, LLC. 3 Exemption from Section 333 

## TA **BLE OF**

**CONTENTS Page**  GLOSSAR

Y OF ABBREVIA

TIONS................................................. ...............................4

INTRODUCTION AND BACKGROUND OF PETITIONER.......... ...............................5

NAME AND ADDRESS OF PETITIONER.......................................

.. .............................5

THE SPECIFIC SECTIONS, EXTENT OF RELIEF , AND REASON FOR RELIEF OF 14 C.F .R. FROM WHICH SEI, LLC SEEKS EXEMPTION............................................ 5

THE REASONS WHY

GRANTING SEI, LLC'S REQUESTWOULD BE IN THE PUBLIC INTEREST

.................................................................................................... ...8

THE REASONS WHY

GRANTING THE EXEMPTION WOULD NOTA DVERSEL Y AFFECTSAFETY

........................................................................ ................................... ...9

CONCLUSIO N......................................................................................9



## GLOSSAR

**Y OF**  **A BBREVIA** 

**TIONS**Soaring Eagle Imaging, LLC. 4 Exemption from Section 333

AGL Above Ground Level AOI Area of Interest AT C Air Tr af fic Control AT O Air Tr af fic Organization AV Aerial Ve hicle C.F .R. Code of Federal Regulations COA Certificate of Authorization FA A Federal Av iation Administration FA R Federal Av iation Regulation GCS Ground Control Station GPS Global Positioning System LOL Loss of Link NAS National Airspace System NOT AM Notice to Airman PIC Pilot In Command Section 333 F

AA Modernization and Reform Act of 2012 (FMRA) Section 333 SOP Standard Operating Procedures SEI, Soaring Eagle Imaging, LLC UA Unm anne d Aircraft UAS Unm anned Aircraft System VFR Vi sual Flight Rules VLOS Vi sual Line of Site VMC Vi sual Meteorological Conditions VO Vi sual Observer VTOL Ve rtical Takeoff and Landing

This petition for the exemption is being entered by W illiam Paden, (Owner and Operator of Soaring Eagle Imaging, LLC) and will provide its clients with expertise andSoaring Eagle Imaging, LLC. 5 Exemption from Section 333

knowledge in advanced technologies and applications to increase efficiency , productivity and ef

fectiveness. Mr. W

illiam Paden is a F

AA rated Helicopter Pilot with Airline Tr ansport License privileges; and also a F AA licensed mechanic with Airframe and Powerplant privileges. Mr. Paden has spent many years working in different aspects of aviation from maintenance to operator, civilian and military , in som e of the m ost dem anding situations. The commitment to safety will never be in question. Wi th the granting of this exemption SEI will be able to safely serve the public and government in varying ar eas to provide services not previously available or economical. Contact Information Follows: Wi lliam Paden 133 Glen Arbor Court Brandon, MS 39042 soaringeagleimaging@yahoo.com FA A Certificate Num

ber 3370 180

**1. Extent Of Relief : SEI, LLC**  **Seek s Relief From Section 61.23 (a)**  Relief from Section 61.23(a): Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section. Until a time in which the F AA determ ines rules pertaining to UAS operators, the PIC for SEI, LLC operations will at a mi nim um m aintain a Class 2 medical. **2**
**. SEI, LLC Seek s Relief fr**  **om Section 61.1 13 (a) (b)**  Relief from Section 61.1 13 (a) (b) Private pilot privileges and limitations: Pilot in Command (a) No person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire: nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A pr ivate pilot may

, for com pensation or hire, act as PIC of an aircraft in connectionSoaring Eagle Imaging, LLC. 6 Exemption from Section 333

with any business or employment if: **(1)** The flight is only incidental to that business or employment; and **(2)** The aircraft does not carry passengers or property for compensation or hire. Due to the size and gross weight of the UAS systems utilized, SEI, LLC will not carry passengers or cargo for hire. Relief from this section will not jeopardize safety as all persons designated PIC for SEI, LLC will complete a training program prior to acting as PIC in a manner consistent with the operations specifications as described in this

exem ption and the Tr aining Manual for SEI, LLC. This includes Emergency Tr aining. **3**
**. SEI, LLC seek** **s Relief from Section 61.195 (b) (1) (2) and Section 91.109**  Relief from Section 61.195 (b) (1) (2) A person who holds a flight instructor certificate is subject to the following limitations (b) Aircraft Ratings. A flight instructor may not conduct flight training in any aircraft for which the flight instructor does not hold **(1)** A pilot certificate and flight instructor certificate with the applicable category and class rating, and **(2)** If appropriate, a type rating. Until the F

AA quantifies a category or type rating for UAS systems; All training for UAS operations for SEI, L LC, its Contractors, and Clients will be conducted by trained instructors. The trainer qualifications and training syllabus will be covered in the training manual that may be subm itted to the F AA separately for proprietary reasons. The owner and operator o f SEI, LLC is an Army trained Instructor Pilot with many years of experience. The training program will center on the safe operations of UAS systems within the NAS.Soaring Eagle Imaging, LLC. 7 Exemption from Section 333

**4**
**. SEI, LLC seek** **s R elief from Section 91.7(a).**  **And 14 CFR Part 21 Subpart H**  Section 91.7(a) Civil aircraft airworthiness. No person may operate a civil aircraft unless it is in an airworthy condition. 14 CFR Part 21 Subpart H Airworthiness Certificates The UASs that SEI, LLC intends to operate are not able to meet multiple requirements set forth in both Sections being requested relief from. Therefore, n o designated PIC for SEI will operate an UAS without first ensuring the system is airworthy per the manufacturer manuals and SEI Operations Manual. The operation will terminate if at any p oint it is determined that the UAS is no longer airworthy

. All operations will follow the guidelines set forth in this exemption. **5**
**. SEI, LLC seek** **s Relief from Section 91.121** Section 91.121 Altimeter Settings. Due to the size and use of the UASs operated by SEI, the capability to have on board Altim eter equipment would make the UAS either too lar ge or heavy to efficiently operate. The systems proposed to be used by SEI are e quipped with a barometric pressure sensor and GPS equipment, which automatically en sures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of the GCS. This inform ation will be available for AT C as discussed during operations with in controlled airspace. All operations in controlled will be outlined in the SEI operations manual that m ay be subm itted confidentially to the F AA for proprietary reasons. **6**
**. SEI, LLC seek** **s Relief from Section 91.151** Section 91.151 Fuel requirements for f light in VFR conditions The proposed operations by SEI will be conducted during daylight VMC conditions. Per Section 91.151 no person may begin any flight unless that person has enough fuel to fly to the first point of intended landing and assuming normal cruising speed, to fly afterSoaring Eagle Imaging, LLC. 8 Exemption from Section 333

that for at leas t 20 minutes. The systems used b y SEI are powered by rechar geable lithium ion batteries. The average flight time for all systems, except the Aeyron SkyRanger, is approximately 20 minutes. The SkyRanger has an es timated flight time of 50 m inutes. The SkyRanger will be used as per outlined in the SEI Operations Manual. **7**
**. SEI, LLC seek** **s Relief from section 91.405 (a), 91.407 (a) (1), 91.409 (a) (1) (2), and 91.417 (a) (b)**  Since Sections 91.405(a), 91.407(a) (1), 9 1.409(a) (1) & (a) (2), and 91.417(a) (b) only apply to aircraft with an airworthiness certificate, SEI requests relief from these Sections because the UASs do not require airworthiness certifications. The maintenance program will be overseen by a trained and qualified F AA licensed mechanic with Airfram e and Powerplant privileges. The maintenance program will be outlined in the SEI, LLC Maintenance Operations Manual that may be subm itted to the F AA confidentially for proprietary reasons. All maintenance pr ocedures will adhere to the manufacturer manuals and guidelines. All maintenance will be documented for future inspection by authorized FA A personnel. After any maintenance is performed a flight check will be performed as outlined in the SEI, LLC Maintenan ce Operations Manual. The granting of an exemption for Soaring Eagle Imaging, LLC will be in the best public interest. Use of a UAS can decrease operating cost for business in the fields of marketing and surveying. The public will be afforded the opportunity to use marketing im ages to help sell their products, helping to stimulate local economies and increase business growth. The lar

gest impact will be on research with Government agencies and universities. The UAS will provide aerial imaging at cost far b elow the tradition aerial im aging used in current applications. The granting of this exemption for Soaring Eagle Im aging, LLC will not adversely af fect safety because Mr. Paden has many years working in the Av iation field and Safety is at the core of his business. He has performed maintenance on aircraft used in EMS toSoaring Eagle Imaging, LLC. 9 Exemption from Section 333

transport patients in time critical emergencies and understands how important even the

sm allest task can be for the safest outcome for all parties involved. Mr. Paden is also a FA A Licensed Helicopter Pilot with AT P privileges tasked with carrying passengers for a Part 135 Operator in the Gulf of Mexico. On a daily basis Mr. Paden is entrusted to make decision s on weather, proper documentation, and proper procedures to ensure all personnel ar e safely transported. In addition to a properly trained pilot, all operations will have a Vi sual Observer trained and on hand. No flights will be conducted above 400 feet AGL. The years of experience and safe decision making ensure Soaring Eagle Im aging, L LC will maintain the highest level safety in all aspects of business. In conclusion, the level of experience in all aspects of aviation provide Soaring Eagle Im aging, LLC to perform aerial imaging within the NAS while maintaining a level of safety equal to any other aviation operation. The future of aerial imaging will be deeply affected by Unmanned Aerial Systems and ensuring safety is top priority

. Thank you for your time and consideration in this matter

.
Sincerely , Wi lliam Paden