U.S. Department of Transportation

Docket Management System 1200 New Jersey Avenue, SE Washington, DC 20590

RE: Exemption Request

– Section 333 of the FAA Report Act and Part 11 of the Federal Aviation Regulations

Dear Sir/Madam,

This petition is being submitted on our own behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Modernization Act), and 14 C.F.R. Part 11, Green Sniper, LLC an Oklahoma based lim ited liability company operating a Small Unmanned Aircraft System (sUAS) equipped to conduct aerial photography and survey for various industries, hereby applies for an exemption from the Federal Aviation Regulations (FARs) listed below to allow operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

The request ed exemption would permit Green Sniper, LLC to pursue its commercial interests in providing services to consumers interested in aerial data capture using a small advanced sUAS in the following areas:

• Agricultural Surveying

• Construction Surveying

• Commer cial Surveying

• Gas and Oil Inspections and Monitoring

• Real Estate Photography

• sUAS Operator Training

• Product Demonstrations

• Research and Development

• Aerial Surveying /Inspecting

• General Video and Photography assignments

• Inspection of Wind Towers

• Damage assessments

• Event Marketing Photo and Video

• Education and Training

In addition to the waiver authority provided in Section 333 of the Modernization Act, the FAA may grant an exemption under 49 U.S.C. Section 44701(f) if it has determined that such anex emption is in the public interest.

Granting an Exemption is in the Public Interest. Currently, various businesses must hire traditional manned aircraft in order to obtain aerial

views of their property for inspection and advertising purposes. These manned aircraft pose significant risk to aircraft operators, nearby property, and persons in the area. The use of sUAS for general asset evaluation would reduce the risks to personnel and property by allowing for
remote aerial review. Further, the use of sUAS ha ve the potential to improve efficiency, resulting in faster and safer delivery of asset evaluation, all while significantly reducing the risk of human and property loss.

Regulations from which the exemption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.109

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. 91.205 (b)

14 C.F.R. 91.215 14 C.F.R. (91.401

- 91.417)

An exemption would allow Green Sniper, LLC to broadly evaluate assets and operations with sUAS, resulting in a safer and more efficient inspection and monitoring regime in the resource industries. Accordingly, the grant of an exemption is consistent with Congress’ intent, reflected in Section 333 of the FAA Modernization and Reform Act of 2012 (Modernization Act), that safe systems be permitted in the national airspace prior to the issuance of final regulations governing general use of thes e systems.

This exemption would permit commercial operation by Green Sniper, LLC , which uses DJI
Phantom 3 , DJI Inspire 1, and 3D Robotics Solo sUAS’ to conduct general asset inspections. Green Sniper’s operation under the exemption will be subject to str ict operating requirements and conditions to ensure an equivalent level of safety to currently authorized operations using manned aircraft and under conditions as maybe modified by the FAA as required by Section

333.

Green Sniper, LLC states that all sUAS flights will occur over private or controlled access property, will do so with the property owner’s consent and knowledge, and only people who have consented or agreed will be in the area where flights will take place.Furthermore, the petitioner will on ly operate its sUAS in line

- of

- sight (VLOS) of a pilot and/or

observer and will operate at sites in that are ‘sufficient distance’ from populated areas within
the work area described in the Green Sniper, LLC Operations Operating Manual. Such operations
wil l ensure that the sUAS will not create a hazard to users of the national airspace system or the public.

Additionally, Green Sniper, LLC crew will consist of a sUAS pilot who will hold a FAA private pilot certificate or a sports pilot license, plus a Visua l Observer (VO). In keeping with previous exemptions granted, we will ensure that operations will not occur within 5 miles of an airport. The sUAS operated by Green Sniper, LLC all weigh less than 25 pounds, including payload (i.e. sensors, camera, lens, and stabilized gimbal), and operate at speeds below 35MPH , and will not be ope rated at altitudes that exceed 4 00 feet AGL.

Given the small size of the sUAS and the restricted work environment within which it will
operate, Green Sniper, LLC operations adhe re to the Reform Act’s safety requirements. The fact the pilot holds an FAA Private Pilot license demonstrates Green Sniper’s high regard for safe operations with an understanding of FARs, pre

- flight inspections, knowledge of operations and differences in airspace classifications, maintenance and repair, as well as being trained to high safety standards.

We respectively request exemption under Section 333 to enable Green Sniper, LLC to operate efficient, limited, low

- risk commercial sUAS operations for the activities stated, respecting at all times the space and privacy of citizens and property while keeping airspace safe.

Sincerely,

To dd Ballard Green Sniper, LLC
Stillwater

, OK 74074

( 405 ) 334

- 8221

tab.ballard@gmail.comEXEMPTION REQUESTS AND EQUIVALENT LEVEL OFSAFETY

Green Sniper LLC requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the sUAV System :

14 CFR Part 21, Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimenta l certificate be issued for the DJI Phantom 3, DJI Inspire 1, and the 3D Robotics Solo sUAS under either or both of the following provisions:

21.191 Experimental certificates

. Experimental certificates are issued for the following purposes: (a) Research an d development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to sh ow compliance with the function and reliability requirements of the regulations. Since the experimental certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experi mental certificate would permit our commercial purpose as well. The aircraft will not carry persons or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily of foam, carbon fiber, and/or plastic, we propose that the UA will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this applicat ion, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthiness certificate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Si ze 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 must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAV does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety by i ncluding the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the pe rmanent placard discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin

.14 CFR 61.113 Private pi lot privileges and limitations: Pilot in Command and61.133 Commercial pilot

privileges and limitations. The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Subp aragraph (b) allows a private pilot to act as pilot in command of an aircraft in connection 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. Our proposed operations require that the PIC must hold at least a Private Pilot Certificate issued by the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even thou gh the intent of this application is to conduct a
business.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapp licable.

14 CFR 91.9 Civil aircraft flight 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. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operati ng the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet
th e intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain f light tests. The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The sUAS System ground

- based control station
consists of a small hand

- held radio transmitter and while it does not offer a second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having "hands

- on" the controls during flight, we fe el that this technique meets the intent 91.109 and provides an equivalent level of safety.

14 CFR 91.119 Minimum safe altitudes: General. The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500
feet to an y person, vessel, vehicle, or structure. Since the typical mission of the sUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flo wn over property or persons where permission has been obtained and careful pre

- planned has been performed. The aircraft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to
persons or property on the surface. Therefore, we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption.

14 CFR 91.121 Altimeter settings.
The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prev ent conflict with other aircraft. An Above Ground Levelaltimeter measurement above the takeoff point is transmitted via radio from the sUAS on

- board

computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions. The regulation provides that no person may begin a flight in an airplane under day

- VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragra ph is to provide an energy reserve as a safety buffer for delays to landing. The sUAS are battery operated and the maximum duration of flight from a single battery charge is 12

- 45 (depending on which sUAS) minutes with a 20% reserve. Since the aircraft wil l never fly more than 1/2 NM from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". We also request exemption from the 30 min reserve and ask that our reserve will be to fly the mission to the point of intended landing and have at least a 20% battery reserve after that.

14 CFR 91.203(a) & (b) Civil aircraft: Cert ifications required. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph(b) provides
that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." With our largest vehicle, the RF

- 70, at a maximum gross weight of 13 pounds, the sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be co

- located with the crew at the ground control stat ion and available for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information p lus the word "EXPERIMENTAL" to satisfy the requirement of 14 CFR45.23.

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventive Maintenance, Alterations

. The regulation provides that the operator is primarily responsible for maintaining the aircraft i n an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service ." The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition

, conduct detailed inspectio ns after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating
software and firmware for the on

- board computer. All other maintenance will be pe rformed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.