U.S. Department of Transportation

Docket Management System 1200 New Jersey Ave., SE Washington, D.C. 20590
**Petitioner:** SunSweep Manny Teran President and CEO 2102 N. Forbes Blvd., Suite 101 Tucson, AZ 85745 manny.teran@aztera.com Submitted On : 7/21/2015

Dear Sir or Madam: With regards to Section 333 of the FAA Modernization and Reform Act of 2012, SunSweep hereby applies for an exemption from Federal Aviation Regulations (FARs) to allow commercial operation of its small Unmanned Aerial Systems ( s UAS). SunSweep will use said s UAS to monitor and gather data on solar farms, using infrared imaging, in order to detect inefficiencies of photovoltaic cells, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333. **Exemption	sought:** SunSweep respectfully requests the grant of an ex e m ption to the following specific sections of the Title 14 Code of Federal Regulations (14 CFR) allowing it to operate lightweight UASs for commercial use: §§ 6 1.23(a)(3) ; 61.101(e)(4) and (5); 61 .113(a); 61.315(a); 91.7(a); 91.9 (b)(2); 91.1 19(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) and (b). **Proposed	Aircraft:** If chosen for exemption, SunSweep will use the following sUAS to perform necessary operations:

 AirRobot AR200 (see Figure 1.0) The AirRobo t AR200 is a multi
-rotor, vertical takeoff and landing, small UAS, with a gross weight of 18.5 lb. With a maximum payload capacity of 7 lb., the maximum possible weight of the UAS (with infrared camera and other payloads attached) will be much less than 55 lb. The AR200’s maximum commanded airspeed, under GPS control, is 35 mph, with a cruise speed of 18 mph. The AR200 utilizes six maintenance
- free brushless and gearless electric motors. With a modular payload concept, the AR200utilizes digital data transmission and control on a real
-time basis. An example of what the flight path may

look like, as well as the software used to operate the sUAS, can be found in the appendix (see figure 2.0).
**AirRobot	AR200	Safety	Features:** Lost CC Uplink
- User selectabl e. Under GPS

– Wait 20 sec, Climb to highest altitude reached on way to current position, Turn towards Home (Take Off Position or Custom Position), Fly Home. ALTERNATIVE: Initiate auto landing. Without GPS availability
- initiate auto landing. Battery Failure - In case of battery failure, unit will initiate a slow (0.5 m/s) auto landing. Unit always preserves enough battery power to ensure safe landing with all sensors and stabilization systems working. Processing and Stabilization
- All processing for auto positioning and auto stabilization is built into the unit. The unit does not need radio communication to maintain this functionality. No processing is performed on the ground station. Waypoints are pre fed onto onboard memory. Operator Error
- Unit has envelope protection and does not allow maneuvers, which could lead to crash like over steering or exceeding maximum angle of 25 degrees. Safety Ring
- Flexible protection ring allows for operation extremely close to subjects of interest without risk of damage to the rotors. Black Box
- All AirRobot systems have onboard flight data recorder (black box). Data is stored on MicroSD memory card. Data contains all flight relevant data, including Link quality, Orientation, Altitude, Speed, Direction and in addition battery status, engine rotation speed for each engine, GPS position. All data is time stamped with GPS time. **Public	Benefit:** Manned aircraft conducting aerial surveying operations can weigh thousands of pounds or more and are operated by an onboard pilot, in addition to other crewmembers as necessary. SunSweep will only use UASs that weigh less than 19 pounds. The pilot/operator will control the aircraft remotely, from a location on the ground. The aircraft’s light weight and the absence of an on
-board pilot reduces the potential for personal harm or damage to property in the event of an accident or malfunction. The UAS is also an environmental benefit to the public. Seeing as it is purely electronically powered, no fossil fuels will be used, leading to the non
-use of unrenewable resources and the elimination of harmful emissions or spillages. Finally, the service that SunSweep plans on providing using the AR200 will positively benefit the public’s energy demands. Solar fields continue to provide an increasing amount of renewable, electricpower to the public, however, the solar panels can malfunction or be damaged which leads to

inefficiencies in generating power. With the use of the AR200 , SunSweep will identify these inefficiencies and allow for necessary repairs to be made in a timely fashion, leading to the most efficient solar power grid possible. **Relief	sought and	reason**  **for	relief :**  SunSweep intends to use a sUAS for commercial purposes, which will include thermal imaging of solar panels , and digital surveying of solar fields. This relief is sought because civil/commercial use of UASs is currently prohibited by FAA laws and regulations, unless granted an exemption. **§61.23 (a) (3):**  **Medical certifi cates: Requirement and duration**  (a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section, a person
— (3) Must hold at least a third
- class medical certificate

— (i) When exercising the privileges of a private pilot certificate; (ii) When exercising the privileges of a recreational pilot certificate. SunS weep may use a pilot with either their recreational or private pilot’s license
. SunSweep believes that the herein proposed operations of the AR200 fall s into the category of § 61.23 (b), which does not require a medical certificate for operation, much like a sport pilot operating a balloon or glider. Because there will be minimal inh erent medical risks during the operation of the aircraft

– on private, unpopulated property, with only company employees being involved in operations

– requiring the pilot to obtain a medical certificate beyond their appropriate operational tasks is not ne cessary. SunSweep’s pilot will maintain the appropriate medical certificate requirements in correspondence with the type of pilot’s license he/she holds. **§61.101 (e) (4) and (5): Recreational pilot privileges and limitations** (e) Except as provided in paragraphs (d) and (i) of this section, a recreational pilot may not act as pilot in command of an aircraft

— (4) For compensation or hire; ( 5) In furtherance of a business. This regulation prevents someone with a recreational pilot’s license from operatin g an aircraft for compensation, or in the furtherance of a business. SunSweep seeks relief from this regulation so it can hire or contract a qualified pilot to operate the AR200 for compensation. Concurrently, the pilot’s operation of the aircraft will contribute towards the furtherance of SunSweep as a for
-profit entity. **§61.113 (a): Private pilot privileges and limitations: Pilot in command** (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private pilot certifi cate 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. This regulation, much like the previous, prevents a pe rson with a private pilot certificate from operating an aircraft for compensation as pilot in command of that aircraft. While SunSweep will not be using the AR200 to carry either passengers or property (only SunSweep
- owned payload sensors), the pilot in co mmand will be receiving compensation for their efforts.**§61.315 (a)**  **: What are the privileges and limits of my sport pilot certificate?**

(a) If you hold a sport pilot certificate you may act as pilot in command of a light
- sport aircraft, except as specified in paragraph (c) of this section. (c) You may not act as pilot in command of a light
- sport aircraft: (2) For compensation or hire. (3) In furtherance of a business. Similar to rule § 61.101, this regulation prevents a person with a sport pilot certificate from operating a light
- sport aircraft for compensation for in the furtherance of a business. SunSweep may hire a pilot in command with a spo rt pilot certificate in order to operate the AR200. Therefore, exemption is sought so SunSweep may utilize the pilot’s skills to further the business, while compensating the pilot through payroll or contracted funds. **§91.7 (a): Civil aircraft airwor**  **thiness** (a) No person may operate a civil aircraft unless it is in an airworthy condition. This regulation states that no person may operate a civil aircraft unless it is in an airworthy condition. Because SunSweep intends to operate the AR200 without an airworthiness certificate, there will be no recognized FAA standar d for determining airworthiness, merely the PIC’s judgement during inspection before flight operations. **§91.9 (b) (2):**  **Civil aircraft flight manual, marking, and placard requirements** b) No person may operate a U.S.
-registered civil aircraft

— (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, appro ved manual material, markings, and placards, or any combination thereof. This rule requires the on
-board presence of a rotorcraft flight manual (seeing as the AR200 is a multi
rotor aircraft). SunSweep cannot comply with this requirement for the ope ration of the AR200 because the AR200 is too small to carry any information or approved materials on
-board during operations. However, the AR200 comes with access to online manuals that pro vide instructions for the safe operation and maintenance of the aircraft. In addition, the pilot on the ground will maintain a hard copy of the aircraft operations manual, as well as documents regarding proposed flight patterns. **§91.119 (c): Minimum safe altitudes: General**  Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 5 00 feet to any person, vessel, vehicle, or structure. This requirement restricts the operation of an aircraft below 500 feet above surface level over areas that are not classified as congested areas. It does grant an exemption for the operation below 500 feet in areas over sparsely populated areas, as long as the aircraft remains 500 feet away from any persons or structures. In the case of SunSweep, all operations will take place in sparsely populated areas, on privately owned land. The maximum altitude of operation will remain below 500 feet AGL, and there will be instances when the AR200 will come within 500 feet or less of the PIC, other company personnel, and structures such as solar panel arrays. For example, the AR200 will be within inches or feet of the PIC during inspection and take
- off, and most likely within 500 feet of the designated visual observer at alltimes during operation. In these instances, and any instances where the AR200 comes within 500 feet of

employees not involved in the operation, a proper audio alert system will be used to notify any employees of the aircraft’s proximity , to ensure proper safety and operation. Due to the nature of the aerial data SunSweep will collect, it will be necessary to operate the AR200 anywhere between 10 and 400 feet away from a solar panel , which qualifies as a structure . For these reasons, SunSweep requests exemption. **§91.121: Altimeter settings** (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimet er that is set, when operating

— (1) Below 18,000 feet MSL, to

—(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft; (ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate availabl e station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before departure; or (2) At or above 18,000 feet MSL, to 29.92 ′′ Hg. (b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as shown in the following table: (c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number of feet specified below, according to the current reported altimeter setting. This regulation requires the operator of an aircraft not equipped with a radio to main tain a cruising altitude by referencing an altimeter that is set to the elev ation of the departure airport or an appropriate altimeter setting. The AR200 is not equipped with an altimeter, but is instead controlled via GPS signals. The pilot in command will operate the aircraft using a hand
-help control and visual displays

– the altitude of the AR200 will be shown on a screen to the operator and thus re ferenced. SunSweep seeks an exemption for this reason. **§91.151 (b)**  **: Fuel requiremen**  **ts for flight in VFR conditions** (a) No person may begin a flight in an aircraft under VFR conditions unless (considering wind and forecast weather conditions) there is en ough fuel to fly to the first point of intended landing and, assuming normal cruising speed

—( 1) During the day, to fly after that for at least 30 minutes. This regulation requires that an aircraft carry enough fuel t o reach the first point of its intended landing and fly for at least 30 minutes during daylight hours. The AR200 does not use gas but instead utilizes electric power using Lithium polymer batteries of 34 V and 746 Wh c apacity . The AR200 has a maximum endurance of 50 minutes using a full charge, and once drained the batteries have a recharging time of two hours for full capacity . If SunSweep was to follow this rule, it would only be able to operate for 20 of its total 50 minutes of battery charge in order to meet the required 30 minute cushion. F or this reason, SunSweep seeks exemption in order to fly the AR200 for the maximum possible duration recommended in the operations manual, in order to collect the maximum possible data during the fewest number of flights, before returning it to charge. The aircraft will not be flown beyond its battery capability, allowing it ample time to safely return to its planned landing position

– prior to full batter drain

– to begin recharging.***** **§91.405 (a): Maintenance required**

Each owner or operator of an air craft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescr ibed in part 43 of this chapter. ***** **§91.407 (a) (1): Operation after maintenance, preventive mainten**  **ance, rebuilding, or alteration** (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been approved for re turn to service by a person authorized under §43.7 of this chapter
. ***** **§91.409 (a) (1) and (2): Inspections**  (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless

— (1) It has been app roved for return to service by a person authorized under §43.7 of this chapter; and (2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has been made. ***** **§91.417 (a) and (b): Maintenance records** (a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alteration and reco rds of the 100
-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an airc raft. The records must include

— (i) A description (o r reference to data acceptable to the Administrator) of the work pe rformed; and (ii) The date of comple tion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life
- limited parts of each airframe, engine, p ropeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overha uled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under wh ich the aircraft and its appliances are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or sa fety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following reco rds for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 ye ar after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under §43.11 of th is chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. * An exemption to these above regulation s of required maintenance is sought because the ab ove mentioned section s require an inspection either b y an authorized person under 14 C.F .R. Part 43 or pursuant to the acquisition of an airworthiness certificate. SunSweep will be using the Pilot in Command to maintain and inspect the AR200 before, after, and between all flights, which includes visual inspe ctionand pre
- flight testing, rather than using an authorized agent (seeing as the UAS will lack an airworthiness

certificate) . The operator will comply with the operations manual provided by AirRobot regarding the proper maintenance and inspection of a sm all multi
-rotored UAS. The operator will also keep records on flight operations and maintenance to the AR200, in accordance with the operations manual. In an event that maintenance is necessary, but operator maintenance is not advised, the aircraft will be sent back to AirRobot for servicing. **Equivalent	Level	of	Safety:** SunSweep proposes operations of the AR200 under the following limitations, which provide at least an equivalent (or higher) level of operational safety to the current regulatory structure
. Many of these limitations are referenced from Exemption No. 11800, Regulatory Docket No. FAA

–2015

– 1020 , because they are also applicable to the situation(s) proposed for exemption by SunSweep.

 Safety will be the primary consideration during any operation of the AR200  The operator is an FAA licensed pilot, and will be designated Pilot in Command whether operating or supervising the AR200.  Flights will be operated within the visual l ine of sight of the PIC or visual observer.  The AR200 weighs less than 55 pounds in total, with payload.  The aircraft will be operated strictly within Class G airspace during all operations, at a maximum altitude of 200 feet AGL (or below)
.  Flights will be operated under visibility and cloud clearance requirements equiv alent to Visual Flight Rules (VFR).  The AR200 will strictly be flown during the hours between e sunrise and sunset, with night or in clement weather use.  Minimum crew for each operation will consist of the sUAS PIC and if necessary, a visual observer (VO). The visual observer and PIC will at all times b e able to communicate by voice if both are operating
.  All personnel, including contractors in the arrays also carry UHF MURS radios to accommodate communications between flight team and site personnel at any time.  There is no general public area over which the UAV would be flown , only privately owned land where the solar farms are located
. All personnel who may be near the flight operation will be company employees.  In the event that the minimum operating distance of 500’ f rom any unsheltered personnel is unable to be maintained, the operations will be immediately ceased as safely as possible. .A ll personnel will be briefed on the operational areas and associated hazards during daily job hazard an alysis briefings.  Prior to an AR200 flight, an area of operation will be established. This area of operation will include a defined lateral and vertical area, where the sUAS will operate. Safety procedures will be established for persons, property and app licable airspace within the area of operation.  The sUAS aircraft used will utilize GPS navigation  A briefing will be conducted in regard to the planned sUAS operations prior to operation at each new location. All personnel who will be performing duties wit hin the boundaries of the area of operation will be present for this briefing. Written permission from the relevant property owners will be obtained prior to an operation.  Prior to each flight, the PIC will inspect the AR200 to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the sUAS, the sUAS will not be operated until the necessary maintenance has been p erformed and the sUAS is found to be in a condition for safe flight. All maintenance and alterations will be properly documented in the aircraft records.  The operator will follow the sUAS manufacturer’s aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements.  If multiple AR200’s are used in SunSweep’s services, each aircraft operated under this exemption will comply with all manufacturer Safety Bulletins. **Summary** SunSweep wishes to utilize Unmanned Aerial System tec hnology to perform aerial imaging of solar fields with a commercial intent. The specific UAS that will be used in the AirRobot AR200, which, based on its official specifications, qualifies as a small UAS. SunSweep believes that the AR200’s size and speed, operating environment, limitations , and level of PIC’s experience provide an “equivalent level of safety” or better when operating a sUAS for the public interest as outlined in Section 333 in the FAA Modernization and Reform Act of 2012. It is requested th at the FAA issue an exemption to permit safe, legal, commercial sUAS operation by SunSweep as soon as possible. The specific sections of the Title 14 Code of Federal Regulations (14 CFR) that SunSweep requests exemption from are as listed below: §§ 61.23( a) (3 ); 61.101(e)(4) and (5) ; 61.113(a); 61.315(a); 91.7(a); 91.9 (b)(2); 91.119(c); 91.121; 91.151(a)(1); 91.405(a); 91.407(a)(1); 91.409(a)(1) and (2); 91.417(a) and (b). Thank you, Manny Teran President and CEO SunSweep / Aztera**Appendix :** 

Figure 1.0

Figure 2.0