### December 17th, 

### 2015 U.S. Department ofTransportation Docket Management System 1200 NewJersey Avenue, SE Washington, DC 20590 

### we define, design 

## &deliver the places where you play, live &work pierson land works LLC www.piersonlandworks.com 

### SUBJECT: Request for Exemption underSection 333 ofthe FAA Modernization and Reform Act of2012 and Part 11 of the Federal Aviation Regulations from Certain Provisions of 14 C.F.R. 

### Petition Summary Pursuant to Section 333 ofthe Federal Aviation Administration (FAA) Modernization and Reform Act of 2012 (FMRA), Pierson Land Works, LLC (PLW) hereby petitionsforexpedited approval and exemption from FAA authorizing commercial operation ofits small unmanned aircraftsystems (sUAS) for remote sensing, aerial surveys, data and imagery collection forthe industries and functions listed in Table 

### 1. T

able 1: Industries Served: Aerial Photography Mining Agriculture Planning 

### &Asset Management Bridges 

### &Roads Promotion 

### &Marketing Engineering Services Real Estate 

### &Land Development Environmental Monitoring Training 

### & Education Inspections Transportation 

### & Infrastructure Land Surveying Other Flight Operations Ifgranted, the exemption would permit PLW to conduct commercial operations ofsmall unmanned aircraft systems (sUAS) that meetorexceed operational and safety requirements set forth by Congress in Section 333. PLW is a land surveying, landscape architecture, GIS mapping, and land planning company based in Jackson, Wyoming, with satellite offices in Idaho Falls and Driggs, Idaho. Our staff members are highlytrained and specialize in providing high
-resolution, accurate spatial data and offerconsulting services to ourclients. PLW strives to provide innovative products to our clients who demand these types ofservices to accelerate in their industry. Unmanned Aerial Vehicle (UAV) technology and the data it can provide have become highly sought after in the land surveying industry. Traditional GPS data collection, available imagery, and surface models lack resolution and accuracy necessary for elite project planning, assessments and hazard identification. UAV collected data allows aconsultantto depictthe project area with greateraccuracy, resolution and efficiency to better help clients with project design and analysis. Equally as important, the UAV aspect reduces the amount oftime employees mustspend in perilous environments. Given the technical specifications ofthe sUAS and the rural, sparsely populated environments ofourworkspace, PLW believes it is relevantto use the Academy of Model Aeronautics (AMA) rules to meetthe required level ofsafety ofall operations. The AMA has a proven track record in supervising operations conducted by operators using remote controlled aircrafts and provides the most relevant expertise in terms ofproviding safety guidelines for operators using ultra-light remote controlled aircraft. Operations will be conducted under controlled conditions in airspace that is limited, predetermined, and access controlled. PLW requests operations granted under like conditions and limitations set forth in previous, and similar, Section 333 summary exemptions granted by FAA. wyoming office po box 1143 180 south willow street jackson, 

### wy 83001 tel307.733.5429 fax 307.733.9669 idaho offices 151 n. ridge ave., suite 117, idaho falls, id 83402 tel208.529.5429l pobox680 driggs, id 83422 tel208.354.5429 

### 11 Page

## StatutoryAuthority Section 333 (a) states thatthe FAA "shall determine ifcertain unmanned aircraft systems (UAS) may operate safely in the national airspace system before completion ofthe plan and rulemaking required by Section 332". Section 333 (b) then lists several factors that should be considered in determiningwhich UAS' would be eligible for expedited integration intothe National Airspace System (NAS). Specifically UAS' that "as a result oftheirsize, weight, speed, operational capability, proximityto airports and populated areas, and operation within visual line ofsight do not create a hazard to the users ofthe national airspace system orthe public, or pose athreatto national security." Ifa UAS meets the criteria laid forth in Section 333 (b), Section 333 (c) FAA has the authorityto decide ifan airworthiness certification as specified by Title 49 United States Code, Section 44704 is required foroperation. Section 333 (c) specifically states that the FAA can determine "whethera certificate ofwaiver, certificate ofauthorization, orairworthiness certification undersection 44704 ofTitle 49, United States Code, is required forthe operation of unmanned aircraftsystems." Thus, the FAA has the abilityto allow a UAS that meets the criteria putforth in Section 333 (b) to operate within the NAS without an airworthiness certification as long as the UAS does not pose any hazard orthreatto the NAS, public, and national security. 

## Request for Relief In meeting the aforementioned requirements, PLW requests reliefand exemption from the regulations summarized below: 14 C.F.R. 21 14 C.F.R. 45.23 14 C.F.R. 45.29 14 C.F.R. 61.3 14 C.F.R 61.113 (a) 

### & (b) 14 C.F.R. 61.133 (a) 

### & (b) 14 C.F.R. 91.7 (a) 

### & (b) 14 C.F.R. 91.9 (b)(2) 14 C.F.R. 91.103 (b) 14 C.F.R. 91.109 (a) 

### & 91.319 (a)(1) 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 CFR Subpart E(91.401- 91.417) 

## Unmanned Aircraft Systems PLW is requesting an exemption to operate a DJI Phantom 3 and Inspire, Trimble UX5 

### & UX5 HP and eBee senseFiy. PLW's sUAS proposed foroperations through this request, all weigh less than 55 pounds, fly at speeds of no morethan 100 miles per hour (MPH), carry neithera pilot nor passenger, carry no explosive materials orflammable liquid fuels, and will operate within approved flight areas and heights through coordination and communication with the Flight Standards District Office (FSDO), AirTraffic Organization (ATO), airtraffic control facilities and personnel, and any other entities or persons to satisfy terms set forth by the FAA forthis exemption request. 

## DJI Phantom 3 Professional 

## &Inspire The DJI Phantom 3 Professional Quadcopter (P3P) and Inspire are vertical takeoffand landing (VTOL) Unmanned Aircraft Vehicles (UAV) with a Ground Control Station (GCS) utilizing electronictablet orsmart phone systems. The P3P is asmall (23 x 23 inches) and ultra-light (maximum take-offweight of2.82 lbs.) quadcopter made of lightweight plastic with a maximum speed ofapproximately 16.4fps. The P3P performs pre-programmed precision aerial mapping missions with the on-board GPS and the related flight management software (DJI go) that allows the operatorto plan safely and efficiently a mission in 3D, and monitor it in real-time. With an attached camera, the P3P takes a collection of 21 Pagehigh-definition still images and video. It is equipped with four main rotors, powered by lithium polymer batteries manufactured by DJI. GPS and GLONASS combine to make the P3P completely aware of its location. It hovers precisely, moves accurately, and locks onto satellites faster and with the DJI GO app, we can track its location on a live map, and record the takeoff point so we can bring it back with the tap ofafinger, providing us a worry-free flight experience. The OJI Inspire's dimensions are 22 x 23 inches. It is lightweight and flexible builtfrom carbon fiberand has a fully integrated intelligent battery powered system thatvirtually manages itself. When in flight, the battery power is shown live, indicating how longyou can continue to fly. Advanced algorithms calculate the distance ofyour aircraft and estimated time to return home, lettingyou knowwhen it'stime to fly back. It is also equipped with an Inertial Measurement Unit (IMU), which keeps the Inspire stable and steady duringflight. The IMU incorporates both a 6-axis gyroscope and an accelerometerto monitor miniscule changes in tilt and movement. This allows the aircraft to compensate and adjust immediately, holding its position at all times. The Inspire 1 can be placed on autopilot when needed. lfthe battery runs low orconnection with the remote is lost, the inspire uses its positioning system and smart flighttechnologyto return back to home.

The following is representative offailsafe emergency procedures available with both ofthe DJI sUAV's.

• Loss ofCommunication: Ifthe communication linkwith the PIC/operators ground control station is lost, the platforms will initiate a return to home mode afterthree seconds oftransmission loss. • Low Battery: Initiated automatically based on remaining battery life, altitude, and distance from home pointwhen the battery level is low awarning alertsthe PIC/operator and the aircraftwill automatically begin a return to home procedure. • Loss ofGPS: Losing a GPS signal while flying autonomouslywill triggerthe aircraftto hover using onboard altitude sensing. The PIC can then land the aircraftas soon as possible. DJI is aglobal leader in the sUAS marketwith thousands oftheir products in use for professional and recreational purposes. Given their extensive use and reliability, PLW asserts that the P3P and Inspire platforms can operate safely in the National Airspace System {NAS) through their appropriate use and operations in accordance with PLW's training and operating parameters. The Petitioner has supplied the following additional Information as appendices for consideration ofthis request: • DJI Phantom 3 Professional User Manual (Appendix A) • DJI Phantom 

### 3 Professional Intelligent Flight Battery Safety Guidelines (Appendix A) • DJI Phantom 

### 3 Professional Safety Guidelines (Appendix A) • Inspire 1 User Manual (Appendix B) • Inspire 1 Safety Guidelines (Appendix B) • Inspire 11ntelligent Flight Battery Safety Guidelines {Appendix B) • Inspire 1 Maintenance Manual (Appendix B) 

### Trimble UXS/UXS HP The Trimble UXS/UXS HP are small (39 inches by 26 inches) and lightweight (5.51lbs) fixed wing UAS's built with foam and carbon frame materials. They are catapult launched and require no runway fortake-offor landing. The Trimble UXS and UXS HP set the standard forfast and safe aerial data collection by offering a complete system with powerful technologies such as a robust design, a radically simplified workflow and reversed thrust 

### & automaticfailsafe procedures. The UXS/UXS HP has extensive flight experience and a history ofoperational success. The UXS/UXS HP functions primarilyto provide aerial imagery and remote sensing capabilities using one ofa selection of interchangeable camera lenses. High resolution imagery enable data collection, extraction, and analysis from imagery produced by the camera with application to numerous industries such as surveying, architecture, engineering, agriculture, planning, and transportation. Information gleaned from the imagery will help in countless ways like maximizing crop yields, improving response times and coordination following natural disasters, enhanced decision making and overall efficiencies among several industries ranging from real estate, planning, asset management, and 3I Pagemore important, will provide us with higher qualitydata compared to what is available to us now. Practically speaking, all ofthese provide great benefitto the economy and the overall public. Priorto each flight, the Pilot in Command {PIC) will set dimensions ofa designated flight area and relevant flight parameters to ensure the UXS/UXS HP operates within the lateral, notto exceed visual line- of-sight {VLOS), and vertical, notto exceed 400 feet AGL, geographic limits ofan approved site foroperation. In the event a critical issue is detected i.e: a low battery state or loss ofdatalink, the UXS/UXS HP will immediately initiate a return-to-launch/home sequence. Each ofthe sUAS platforms described above is equipped with advanced sensors and high definition cameras. They also have built-in capabilities to limitflight altitude above ground level {AGL) and the radius distance flown from the pilot/operator. In addition, each ofthe UXS/UXS HP's integrated safety features designed to help ensure the safety of persons and property within and surrounding an active operation area. For instance, as described above, ifone ofthe aircraft loses communication with its ground control station orglobal positioning system {GPS) the aircraft can autonomously return to a pre-determined location. The Petitioner has supplied the following additional Information as appendices for consideration ofthis request:

• Trimble UXS Aerial Imaging User Guide (Appendix C) • Trimble UXS Data Sheet (Appendix C) • Trimble UXS HP Data Sheet (Appendix C) 

## eBee senseFiy The eBee is a small {37.8 inches wingspan) and ultra-light (maximum take-offweight of 1.7 pounds) platform made of flexible foam that performs pre-programmed precision aerial mapping missions thanks to the on-board GPS and the related flight management software (eMotion). eMotion allows the operatorto plan safely and efficiently a mission in 3D, and then monitors it in real-time. The embedded camera, protected by afoam envelope takes a collection ofhighdefinition still images that are used laterto generate maps and contour lines ofthe surveyed area. The four main characteristics ofthe eBee are:

• Very lightweight: The ebee is so lightthatthe PIC can launch it by hand and itwill land on almost any surface without requiring a parachute or landing net. Its low impactenergy also significantly reduces the risk of hazardous situations. The wings ofthe eBee are detachable and made offlexible foam with no sharp or hard edges and almost no internal strengthening structure. • Electric-Powered: The eBee is electric powered. The propeller is attached with a rubber band tothe body ofthe plane so that it can easily flex away in case ofcontact with any object. The engine is silent and reliable. • Semi-Automatic Flight: The artificial intelligence incorporated within the eBee autopilot system continuously analyzes data from the Inertial Measurement Unit and from the onboard GPS and takes care ofall ofthe aspects ofthe flight underthe supervision ofthe operator. • Option for Manual Control: The eBee provides an override capabilitythat allows the operatorto take manual actions during the flight {Go to Home, Go Land, Hold, and Resume the mission) and also suspend automated operations and take manual control ofthe aircraft should it become necessary to respond in an emergent circumstance, thanks to the ground control station provided with the system. The Petitioner has supplied the following additional Information as appendices for consideration ofthis request: • eBee senseFiy User Manual (Appendix D)

41 Page

## Aircraft Marking Each of PLW's sUAS will be identified by a serial number, registered in accordance with 

### 14C.F.R. Part

### 47, and have an identification (N-Number) marking displayed as large as practicable in accordance with 

### 14 C.F.R. Part

### 45. 

## Pre-flight Inspection, Maintenance Before each flight a PLW PIC will perform a series ofpre-flight and takeoffchecks as defined by the manufacturer noted in the Appendices provided. Routine inspection ofall aircraft components, including, but not limited to the items listed belowwill take place:

• Motors, wiring and connectors • Propellers, smooth (no chips) • Batteries, wiring and connectors • Remote command and control • Ground control station 

## UAS Operating Parameters PLW PICs and visual observers, present during any and all flights, will ensure all operation remain within VLOS. Flights will be limited to 400feetAGL- which is accurately measured by GPS. PLW's sUAS operators and PICs are well equipped and trained foroperations sought in this exemption. Communication and coordination with the appropriate FSDO will take place priorto operations, as needed. Further coordination will take place, as required, with the AirTraffic Organization to obtain a Certificate ofAuthorization (COA) priorto any operations granted in this requested exemption. PLW's sUAS will not operate within 5 nautical miles ofan airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) orfor airports not denoted with an ARP, the centerofthe airport symbol as denoted on the current FAA published aeronautical chart, unless a letterofagreement with that airport's management is obtained orotherwise permitted by a COA issued to the exemption holder. The letterofagreement with the airport management must be made available to the Administrator or any law enforcementofficial upon request. PLW's sUAS operations will remain clear and yield to the right ofway ofall manned aircraft operations and activities (including, but not limited to, ultralightvehicles, parachute activities, parasailing activities, and hangliders). Additionally, agrantofthe exemption to PLW to operate theirsUAS will be subject to the following operating conditions. These are based in part on the operating conditions setforth by the Academy of Model Aeronautics.

• Operations to be conducted over private, controlled-access, or public propertywhere approved; • Permission from the land owner/authority required before commencing any flight; • Operations over congested areas shall be avoided to the extent possible; • Operations must not interfere with manned aircraft operations, mustyield the right ofwayto manned aircraft, and operators must See 

### & Avoid otheraircraft and obstacles at all times; • Operations limited to Visual Flight Rules Meteorological Conditions (VMC) and daylight hours • Aircraft operations must remain within Visual Line ofSight (VLOS) and will be visually monitored by the PIC and/orVisual Observer at all times; • All operations conducted within 

### 5 miles from an airportshall only be initiated afterverbal coordination with the airportauthority, orairtraffic control when a control tower is present atthe airport; 

## Pilot in Command (PIC) Any PLW PIC/operator underthis grantofexemption will hold, at a minimum, a sport pilot certificate. The PIC mustalso hold a current FAA airman medical certificate oravalid U.S. driver's license issued by a state, the District ofColombia, Puerto Rico, aterritory, a possession, orthe Federal government. The PIC will also meetflight review requirements specified in 

### 14 CFR § 

### 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate. 

## 5I PageRegarding PLW's requested relieffrom 14C.F.R. § 91.103(b)(1), the unmanned aircraft PIC/operatorwill comply with applicable procedures and requirements stated in§ 91.103{a) and (b). Specifically, PLW PIC/operators will initiate all necessary actions including review ofweather conditions, flight time and battery requirements, aircraft performance data, and landing and takeoffdistances before each flight. Any site-specific conditions will also be planned and considered during preflight procedures and considerations. 

### Radio Frequencies Radio frequencies used will be those allotted by the Federal Communications Commission (FCC) for data transmission and vehicle control in unlicensed frequency bands. All devices used will comply with FCC usage and emissions regulations. 

### Safety and Benefits ofthe UAS PLW plans to operate theirsUAS in avariety ofapplications that generallywould require flying expensive, full-size manned aircraftto successfully conduct a mission or project. Small, light, unmanned aircraftvehicles and their systems offercountless benefits overthe use offull- sized manned aircraftto numerous industries leveraging productsfrom aerial surveys, remote sensing, data and imagery collection. Replacing significantly larger manned aircraft carrying flights crews and flammable fuel with sUAS that do not carry people creates a much greater margin ofsafetyfor sUAS operators and visual observers by contrast to a manned aircrafts flight crew and passengers. The loweracquisition, operational, and personnel costs, in addition to reduced environmental impacts such as reduced noise and emissions, through the use of batteriesfor power- in lieu offuel and combustion engines, are reasons why it is beneficial to the public for PLW to receive FAA authorization to operate its unmanned aircraft. 

### Conclusion For the foregoing reasons, and public benefit, the exemption requested herein should be granted and PLW permitted to conduct small UAS operations in accordance with its manuals and all otheroperating parameters deemed necessary and appropriate by the FAA. Respectfully,

Scott R

. Pierson, PLS, President Pierson Land Works, LLC PO Box 1143 Jackson, Wyoming 83001 307.733.5429

61 Page

## PIERSON LAND WORKS, LLC: EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER APPLICABLE RULES SUBJECTTO EXEMPTION

PLW requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation ofthe sUAS: 14C.F.R. Part 21, Subpart H: Airworthiness Certificates 14CFR § 91.203(a)(1) Section 91.203 requires all civil aircraftto have a certificate ofairworthiness. Part 21, Subpart 

### H, entitled Airworthiness Certificates, establishes the procedural requirements forthe issuance ofairworthiness certificates as required by FAR§ 91.203(a). Given the size ofthe sUAS's, theirweight (the maximum take-offweight is 5.51 pounds) and the limited operating area associated with their utilization, it is unnecessary to go through the certificate ofairworthiness process under Part 21 Subpart H in orderto achieve orexceed current safety levels. Such an exemption meets the requirements ofan equivalent level ofsafety under Part 

### 11 and Section 333 ofthe Reform Act. The Federal Aviation Act and Section 333 ofthe Reform Act both authorize the FAA to exempt aircraftfrom the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximityto airports and populated areas ofthe UAS involved. An analysis ofthese different criteria demonstratesthat the sUAS operated withoutan airworthiness certificate, underthe conditions proposed in that exemption, will be at least as safe, orsafer, than a conventional aircraft with an airworthiness certificate. A proprietary risk assessment for operations with the sUAS, which demonstrates that assertion, is also being submitted to the FAA as partofthis application. PLW requests the FAA treat the sUAS risk assessment as proprietary under 14 C.F.R. 11.35(b) and not include this document in the public docket. 14C.F.R. § 45.23 

### & 14C.F.R. § 45.29: Display ofmarks; size of marks These regulations provide that each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft mustdisplay the word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance to the cabin, cockpit, or pilot station. Given the size ofthe sUAS, this requirement is impossible to match. 14C.F.R. § 61.3: Requirements forcertificates, ratings and authorizations 14C.F.R. § 61.113(a) 

### & (b); 61.133(a): Private Pilot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitations The regulation provides that no person may serve as a required pilotflight crewmemberofa civil aircraft ofthe United States, unless that person: (1) Has a pilot certificate orspecial purpose pilot authorization issued underthis part in that person's physical possession or readily accessible in the aircraftwhen exercising the privileges ofthat pilot certificate orauthorization. However, when the aircraft is operated within aforeign country, a pilot license issued by that country may be used. The regulation provides also that no person that holds a private pilot certificate may act as pilot in command ofan aircraftfor compensation or hire. Subparagraph (b) allows a private pilotto act as pilot in command ofan aircraft in connection with any business oremployment if: (1) The flight is only incidental to that business oremployment; (2) The aircraft does notcarry passengers or propertyfor compensation or hire.

71 PageGiven the safety features ofthe sUAS and the fact that the missions are pre-programmed and monitored in real-time with a specific flight management software, PLW proposes that operators ofthe sUAS should not be required to hold a commercial pilot certification. Instead, operators should be required to: Have at a minimum a sport or recreational pilot license, and be familiarwith the operation and safety guidelines provided by respective UAS's manufacturers. 14C.F.R. § 91.7(a) and (b): Civil aircraft airworthiness (a) No person may operate a civil aircraft unless it is in an airworthycondition. (b) The pilot in command ofa civil aircraft is responsible for determiningwhetherthat aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when an unairworthy mechanical, electrical, orstructural condition occurs. Sections 91.7 (a) and (b) prohibit operation ofa civil aircraft unless it is in airworthycondition. PLW requests an exemption from this regulation because theirsUAS would not operate with an airworthiness certificate underthe proposal setforth in this filing. Given the size ofthe aircraft and requirements contained in the manuals for maintenance and use ofsafety check lists priorto each flight, as set forth in in the operators manual, an equivalent level ofsafety will be provided. The FAA has issued similar exemptionsto this regulation, includingto Tradecraft LLC, Exemption No. 11303. 14C.F.R. § 91.9(b)(2): Civil aircraftflight manual, marking, and placard requirements. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. PLW assumes thatthe intent ofthis requirement is to ensure thatflight manual information is available to the aircrew while operating the aircraft. PLW requests an exemption to this requirement since the aircraft is not onlytoo small to carry documentation; the documentation would not be available to the crew. The equivalent level ofsafety will be achieved by keeping a hard copy ofthe flight manual in the sUAS transportation box. 14C.F.R. § 91.103 (b): Preflight Action This regulation requires each pilot in command take certain actions before flight to ensure the safety ofthe flight. An exemption is needed from this requirement, as the pilotwill take separate preflight actions, including checking for weatherconditions and checking flight battery, and all otheractions in the Operating Manual and safety checklists that accompany the sUAS's. These actions will provide an equivalent level ofsafety. 14C.F.R. § 91.109(a) 

### & 91.319(a)(1): Flight Instruction The regulation provides that "No person may operate a civil aircraftthat is being used forflight instruction unless that aircraft has fully functioning dual controls." Flight instruction will be accomplished through an elaborated training program, using firstthe simulation mode ofthe flight management software. The equivalent level ofsafety during the training will be achieved by the manufactureror authorized distributor providing the training and through the use ofexperienced and qualified operatorsfamiliarwith the sUAS.

8I Page14CFR § 91.119: Minimum Safe Altitudes The regulation provides that over sparsely populated areas the aircraft cannot be operated closer than 500 feetto any person, vessel, vehicle, orstructure. Since the aircraftwill be operating at a maximum of400 feet AGL, the sUAS cannot comply with this requirement. The equivalent level ofsafety will be achieved because the sUAS will onlyfly over private propertywith the permission ofthe landowner. The operatorwill define before every flight a working area radius and aflight area ceiling, preventing the sUAS to go beyond the flight area. The landownerand the persons who may be on the ground in the flight area will be briefed ofthe expected route of flight and the associated risks to persons and propertyon the ground

. Due to the small size ofthe sUAS and the material with which the sUAS is built, the hazard to persons, vessels, vehicles, and structures is not comparable to manned aircraft and should be considered in grantingthe exemption. Moreover, the aircraft will not be operated overcongested areas orover any open-air assembly ofpersons. The aircraft will be operated at an altitude allowing, ifa power unitfails, an emergency landing without undue hazard to persons or propertyon the surface. 14CFR 91.121 -Altimetersettings This section requires that each person operating an aircraft shall maintain the cruising altitude orflight level ofthat aircraft, as the case may be, by reference to an altimeterthat is set, when operating below 18,000feet MSL to:

• The current reported altimetersetting ofa station along the route and within 100 nautical miles ofthe aircraft; • Ifthere is no station within the area prescribed in paragraph (a)(1)(i) ofthis section, the current reported altimetersetting ofan appropriate available station; • In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airport oran appropriate altimetersetting available before departure. To provide an equivalent level ofsafety, the UAS's autopilot calculates the reference altitude (ground level) with the onboard GPS during the pre-flighttests. The GPS and barometer data are merged with respect to their respective precisions. The GPS provides reliable information to correct potential barometric bias, while rapid variations in altitude are detected through the barometer. Hence, barometric bias induced by environmental factors is rejected. 14C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions The regulation provides that no person may begin aflight in an airplane under day-vFR conditions unless there is enough fuel to flyto thefirst point of intended landing and to fly afterthatforat least 30 minutes. Given the area ofoperation forthe sUAS, PLW believes that an equivalent level ofsafety is already achieved with the specific procedure preventing the sUAS to accept atake-offorderwhen the battery level is below agiven value. Moreover, the sUAS have integrated "low" and "critical" battery level warnings and implement a "return to Home" (and "Go Land") actions in these situations. The Phantom and Inspire series battery life provides at most 25 minutes ofpowered flight. Without an exemption from 14 C.F.R. §91.151, flights would be limited to 5 minutes or less. Given the limitationson PLW's proposed operations, a lesser reserve forflight in VFR conditions is reasonable. PLW believes thatan exemption from 14 C.F.R. § 91.151 (a) is safe and consistent with the scope ofa priorexemption. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151 (a)). Operatingthe Phantom and Inspire sUAS without 20 minutes of reserve fuel does not produce the type ofrisks Section 91.151 (a) intended to prevent. Given its weight and construction material, the risks are less then contemplated by the current 9I Page

### regulation. PLW believes that an equivalent level ofsafety can be achieved by the fact thattheirsUAS can safely utilize VTOL capabilityto quickly and safely land within 3 minutes ofan area within VLOS once alerted ofa low battery. Similar exemptions have been granted to others, including Exemptions 2689F, 5745, 10673, and 10808. 14C.F.R. § 91.203 (a} 

### & (b): Carrying Civil Aircraft Certification and Registration 

### This regulation provides as follows: • No person may operate a civil aircraft unless it has an appropriate and current airworthiness certificate. • No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) ofthis section oraspecial flight authorization issued under §91.715 is displayed atthe cabin or cockpit entrance so that it is legible to passengers orcrew. The sUAS's all weigh under5.511bs, (max take-offweight). As such, there is no ability or place to carry certification and registration documents orto display them on the UAS. In addition, there is no pilot or passengers on board the aircraft. To obtain an equivalent level ofsafety and meetthe intent of91.203, PLW proposes thatdocuments deemed appropriate forthis aircraft by the FAA will be co-located with the operatoratthe ground control station and atour office, available for inspection upon request. 14CFR Subpart E(91.401- 91.417}- Maintenance, Preventive Maintenance, and Alterations 

### The regulation provides that the operator is primarily responsible for maintainingthe aircraft in an airworthy condition, including compliance with Parts 39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service by a person authorized under43.7" after maintenance and inspection. Section 91.409(a)(2) requires an annual inspection forthe issuance ofan airworthiness certificate. Section 91.417(a) requiresthe owner oroperatorto keep records showing certain maintenance work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots and records ofapproval ofthe aircraftfor return to service. PLW proposes thatthe maintenance ofthe sUAS's will be accomplished by the owner/operatoraccording to the maintenance manual, provided by the sUAS's manufacturers. PLW requests the FAA treatthe sUAS training program as proprietary under 14 C.F.R. 11.35(b) and not include this document in the public docket. An equivalent level ofsafety will be achieved because the sUAS are small in size, not complex mechanical devices, carries no external payload, and will operate only in restricted predetermined areas. Moreover, the operator is the person mostfamiliarwith the aircraft and is best suited to maintain the aircraft in an airworthy condition and to ensure an equivalent level ofsafety. Finally, before every flight, the sUAS runs automatically asequence ofpre-flighttests to make sure thatevery sensor and every critical part is running properly. Ifa problem is detected, the sUAS will not be able to be switched-on and a message error is displayed on the main screen ofthe flight management software. The operatorcan then refertothe maintenance manual to troubleshootthis issue. Similar exemptions have been granted to others such as TradeCraft, Exemption 11303, Toledo Aerial Media, Exemption 11288, and Skyphilly, Exemption 11256.

10 

## I Page

### Appendix A- DJI Phantom 3 Professional

• User Manual: https://dl.djicdn.com/downloads/phantom 3/en/ Phantom 3 Professional User Manual Vl.G.pdf • Flight Battery Safety Guidelines: http://dl.diicdn.com/downloads/phantom 3/en/Phantom 3 Intelligent Flight Battery Safety Guidelines en. 

## .Pf!f • Safety Guidelines: • http://dl.djicdn.com/downloads/phantom 3/en/Safety Guidelines Disclaimer en 201509.pdf 

### Appendix B- DJI Inspire 1 • User Manual: https://dl.diicdn.com/downloads/inspire 1/en/lnspire%20 1 User Manual Vl.8.pdf • Safety Guidelines: http://dl.djicdn.com/downloads/inspire 1/en/lnspire 1 Safety Guidelines and Disclaimer vl.2 en.pdf • Flight Battery Safety Guidelines: http://dl.djicdn.com/downloads/inspire lien/Intelligent Flight Battery Safety Guidelines en.pdf • Maintenance Manual: http://dl.djicdn.com/downloads/inspire 1/en/lnspire 1 Maintenance ManuaiVl.O en.pdf 

### Appendix C- Trimble UXS/UXSHP • UX5 Aerial Imaging User Guide http://kmcgeo.com/Products/Gatewing/UX5AeriallmagingUserGuide lOOA.pdf • UX5 Data Sheet: http://uas.trimble.com/sites/default/files/downloads/022543

-576b trimbleux5 ds 0615 lr l.pdf • UX5HP Data Sheet: http://uas

.trimble.com/sites/default/files/downloads/022516-131e trimbleuxS hp ds a4 1115 lr

.pdf 

### Appendix D- eBee senseFiy eBee senseFiy Manual • http://www.manualslib.com/manuai/944170/Sensefly-Ebee.html

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