April 8, 2015

Exemption No. 11307

Regulatory Docket No. FAA

– 20 14

– 1018

Mr. Christopher Lawler

Price Aviation Group

422 Blossom Lane

Frederick, MD 21701

Dear Mr. Lawler :

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.

The Basis for Our Decision

By letter dated December 6, 2014 , you petitioned the Federal Aviation Administration (FAA)

on behalf of Price Aviation Group ( hereinafter petitioner or operator ) for an exemption

. The

exemption would all ow the petitioner to operate an unmanned ai rcraft system (UAS) to

conduct aerial photography and inspection

.

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 the 3DR X8+.2

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

finds that 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 Decision

You have requested to use a UAS for aerial data collection . 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 propo rtions, 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 a ll material respects to relief previously requested in Grant of

Exemption Nos. 11062, 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 th e Administrator, Price Aviation Group 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

th e extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

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

Conditions and Limitations

In this grant of exemption, Price Aviation Group is hereafter referred to as the operator.3

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 exemption are limited to the 3DR X8+ 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 picture 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

complia nce 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 o n the PIC’s FAA

- issued airman 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 long 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 fli ght and cannot transfer 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 and limitations stated in this grant of

exemption, are hereinafter referred to as the operating documents. The operating

documents must be accessible during UAS operations and made available to the

Administrator upon request. If a disc repancy exists between 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 operating

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. The4

operator 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 FAA’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 ma intenance or alterations 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 m ay only be conducted 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 discrepancies, 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 with 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 Federal

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, incl uding evasive and emergency 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 operator’s PICs and VOs5

(training, 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 term s of this exemption. However,

training operations may only be conducted during dedicated training sessions. During

training, proficiency, and experience

- building flights, all persons not essential for

flight operations are considered nonparticipants, and the PIC must operate 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 cond itions (VMC). Flights

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

denote d with an ARP, the center of the airport symbol 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 o f agreement with the 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 l ess than 3 statute miles from the PIC.

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

determined location within the private or controlled

- access property.

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

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 minu tes or with the reserve

power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All

operations shall be conducted in accordance with an ATO

- issued COA. The

exemption holder may apply for a new or amended 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 identification (N

Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be

as large as practicable.6

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 rema in clear and 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, vehicles, 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 protection. 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 trainees or essential persons are not considered

nonparticipating persons under this exemption.

27. All operations shall be conducted over private or controlled

- access property with

permission from the property owner/controller or authorized represen tative.

Permission 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 de fined by the applicable COA must be reported

to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be

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 te levision operations manual (MPTOM)

as documented in this grant of exemption.7

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 area 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 ope rator for the UAS aerial filming conducted

under this grant of exemption;

c. Name and phone number of the 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 involved 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 re quest;

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 operation.

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 ex emption, 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.

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

Sincerely,

/s/

John Barbagallo

Acting Deputy Director, Flight Standards ServicePrice&Aviation&Group

Small%UAS%Petition%for%Exemption 1

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

PRICE AVIATION GROUP FOR AN EXEMPTION SEEKING RELIEF FROM THE

REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

CONCERNING OPERATION OF SMALL

UNMANNED AIRCRAFT SYSTEMS PURSUANT TO SECTION 333 OF

THE FAA MODERNIZATION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

Submitted on December 6, 2014

Christopher Lawler

Price Aviation Group

422 Blossom Ln.

Frederick, MD 21701Price&Aviation&Group

Small%UAS%Petition%for%Exemption 2

GLOSSARY

AGL Above Ground Level

ATC Air Traffic Control

COA Certificate of Authorization

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

GCS Ground Control Station

NAS National Airspace System

PIC Pilot In Command

s UAS Small Unmanned Aircraft System

VFR Visual Flight R ules

VMC Visual Meteorological Conditions

VO Visual Observer

VLOS Visual Line of SightPrice&Aviation&Group

Small%UAS%Petition%for%Exemption 3

TABLE OF CONTENTS

GLOSSARY 2

SUMMARY 3

BACKGROUND 3

BASIS FOR PETITION 5

NAME AND ADDRESS OF PETITIONER 5

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PRICE AVIATION

GROUP SEEKS EXEMPTION 5

- 9

THE EXTENT OF RELIEF PRICE AVIATION GROUP SEEKS AND THE

REASON PRICE AVIATION GROUP SEEKS THE RELIEF 9

- 11

THE REASONS WHY GRANTING PRICE AVIATION GROUPS RE QUEST

WOULD BE IN THE PUBLIC INTEREST 11

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

ADVERSELY AFFECT SAFETY 11

- 15

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER 15

CONCLUSION 15Price&Aviation&Group

Small%UAS%Petition%for%Exemption 4

SUMMARY

Price Aviat ion Group (PAG) seeks exemption to operate a s UAS under Section

333 of the FAA Modernization and Reform Act of 2012. This exemption will allow PAG

to operate a UAS for the purposes of aerial photography and inspection in a controlled

, sterile environment. PAG will be op erating a proven airframe to accomplish flights with

an equivale nt or better level of safety to manned operations.

BACKGROUND

PAG is a comp any focused on cost

- effect ive, safe solutions to aerial inspections

and photography

. The company principal is an Airline Transport Pilot and former Line

Check airmen with an accreditation from the American Association of Airport Executives

as a Certified Member. Having firsthand knowledge of the National Airspace system

from the ground and in the air gives PAG a n advantage in operating small UAS. In

addition to flying professionally and understanding airport management, the principal

also has experience in Radio Control (R/C) operations. R/C operations similar to

professional flying require a standard of care t o operate safely from checklists to post

flight review. The standards in PAG operations will mirror Part 121 operations.

Each flight will be carefully coordinated to ensure safe operations as described in

exemptions that have been granted and include d in this petition. In any aviation

operation, the discipline to ensure a safe operation needs to the first priority. PAG will

only conduct flights where the environment can be controlled and no hazard to the public

can occur. This will be accomplished through use of the procedures detailed in this

document.

PAG will be us ing tried and true technology from 3DR to perform appropriate

missions. The 3DR product includes redundancy required by previous exemptions.

Information on the sUAS will be included as an appendix to this document. The

technology that is available from this company includes the necessary restrictions on

performance to comply with FAA requirements:

X8+ Operating Limits

Maximum Altitude* 100'm'(328 ft)

Range* 300'm'(984'ft)'from' launch point

GPS Lock GPS'lock'required'at'all times

Maximum'estimated'flight' time 15 minPrice&Aviation&Group

Small%UAS%Petition%for%Exemption 5

Payload capacity 800 g (1.7 lbs)

( Appendix )

BASIS FOR THE PETITION

In accordance with 14 C.F.R. § 11.81, PAG provides the following information in

support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner is:

Price Aviation Group

422 Blossom Ln.

Frederick, MD 21701

Specific contact information:

Christopher Lawler

422 Blossom Ln.

Frederick, MD 21701

Tel: 570

- 850

- 8924

Email: clawler@priceav.com

B. The Specific Sections Of 14 C.F.R. From Which PAG Seeks Exemption

1. Section 61.113(a) and (b) prescribes that

—

(a) No person who holds a private pilot certificate may act as a 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 private p ilot may, for compensation or hire, 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 forPrice&Aviation&Group

Small%UAS%Petition%for%Exemption 6

compensation or hire.

2. Section 91.103 prescribes, in pertinent part, that each pilot in command shall,

before beginning a flight, become familiar with all available information

concerning that flight, to include

—

(a) For a flight under IFR or a flight not in the vicinity of an airport,

weather reports and forecasts, fuel requirements, alternatives available

if the planned flight cannot be completed, and any known traffic

delays of which the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the

following takeoff and landing distance information:

(1) For civil aircraft for which an approved Airplane or

Rotorcraft Flight Manual containing takeoff and landing

distance data is required, the takeoff and landing distance

data contained therein; and

(2) For civil aircraft other than those specified in paragraph

(b)(1) of this section, other reliable information appropriate

to the aircraft, relating to aircraft performance under

expected values of airport elevat ion and runway slope,

aircraft gross weight, and wind and temperature.

3. Section 91.119 prescribes that, except when necessary for takeoff or landing,

no person may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a pow er unit fails, an

emergency landing without undue hazard to persons or property

on the surface.

(b) Over congested areas. Over any congested area of a city, town, or

settlement, or over any open air assembly of persons, an altitude of

1,000 feet above the highest obstacle within a horizontal radius of

2,000 feet of the aircraft.

(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 clo ser than 500 feet to any

person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft.Price&Aviation&Group

Small%UAS%Petition%for%Exemption 7

If the operation is conducted without hazard to persons or property

on the surface

—

(1) A helicopter may be operated at less than the minimums

prescribed in paragraph (b) or (c) of this section, provided

each person operating the helicopter complies with any routes

or altitudes specifically prescribed for helicopters by the FAA;

and

(2) A powered parachute or weight

- shift

- control a ircraft may be

operated at less than the minimums prescribed in paragraph

(c) of this section.

4. Section 91.121 requires, in pertinent part, each person operating an aircraft to

maintain cruising altitude by reference to an altimeter that is set “to the

ele vation of the departure airport or an appropriate altimeter setting available

before departure.”

5. Section 91.151(a) prescribes that no person may begin a flight in an airplane

under VFR conditions unless (considering wind and forecast weather

conditions) there is enough 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; or (2) At night, to fly after that for at least 45 minutes.

[emphasis added]

6. Section 91. 405(a) requires, in pertinent part, that an aircraft operator or owner

shall have that aircraft inspected as prescribed in subpart E of the same part

and shall, between required inspections, except as provided in paragraph (c) of

the same section, have dis crepancies repaired as prescribed in part 43 of the

chapter.

7. Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an

aircraft that has undergone maintenance, preventive maintenance, rebuilding,

or alteration unless it has been appr oved for return to service by a person

authorized under § 43.7 of the same chapter.

8. Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an

aircraft unless, within the preceding 12 calendar months, it has had an

inspection for th e issuance of an airworthiness certificate in accordance with

part 21 of this chapter.

9. Section 91.417(a) and (b) prescribes, in pertinent part, that

—Price&Aviation&Group

Small%UAS%Petition%for%Exemption 8

(a) 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 records 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 aircraft. The records must include

—

(i) A description (or reference to data acceptable

to the Administrator) of the work performed;

and

(ii) The date of completion 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, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on

the aircraft which are required to be overhauled 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 which 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 complianc e, the AD or safety directive number and

revision date. If the AD or safety directive involves

recurring action, the time and date when the next action is

required.Price&Aviation&Group

Small%UAS%Petition%for%Exemption 9

(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 records 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 year 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 furn ished to a registered owner or operator

under

§ 43.11 of this chapter shall be retained until the defects are

repaired and the aircraft is approved for return to service.

C. The Extent Of Relief PAG Seeks And The Reason PAG Seeks The Relief.

A. Section& 61.113(a)&and&(b):

a. Due&to&the&fact&that&there&are&no&standards&for&private&or&commercial&sUAS&

operations,&

b. Knowledge&of&flight&characteristics&and&the&Federal&Aviation&Regulations&

(FARs),&along&with&the&ability&to&physically&manipulate&the&controls&of&t he&

sUAS&are&the&critical&aspects&of&the&requested&operation.&

c. The&risks&associated&with&the&operation&of&the&sUAS&are&so&diminished&from&

the& standards&that&Part&61&was&written&for&an&equivalent&level&of&safety&can&

be&maintained&with&a&private&pilot&certif icate.&&

d. 4.& FAA&has&authority&to&waive&pilot&requirements&for&commercial&operations&

under&49&U.S.C&§44701(f).

B. 14&CFR&§&91.103&

– Preflight&Action

1. The&PIC&shall&perform&a&preflight&inspection&in&accordance&with&the&

manufacturers&recommendations&of&the& UAS,&controller,&and&Price&Aviation&Group

Small%UAS%Petition%for%Exemption 10

ground&control&station&prior&to&each&flight&to&ensure&it&is&free&of&all&

discrepancies.

2. Equivalent&safety&levels&will&be&met&through&preparation&and&

compliance&with&the& operator’s manual&and&site& preparation

.&

C. 14&CFR&91.119(c)&

– Requi rements&for&Minimum&Safe&Altitudes&for&Civil&

Aircraft&Operation

1. The&sUAS&will&be&operated&only&within&a&predetermined&area&below&

400 feet AGL.

2. 2.&An& equivalent level&of&safety&will&be&maintained.&

D. 14&CFR&91.121&

– Altimeter&Settings

1. SUAS&may¬&have& a&barometric&altimeter,&and&may&use&a&GPS&

altitude&read&out&indication&instead,&so&an&exemption&may&be&

needed.

2. The&operator&will&achieve&an&equivalent&level&of&safety as&the&sUAS&

uses&AGL&height&from&its&initialization&(launch)&point,&cross

^

referenced&wit h&Mean&Sea&Level&(MSL)&altitude&of&the&launch&point.

E. CFR&91.151&(a)(1)&

– Fuel&Requirements&for&Flights&in&VFR&Conditions

1. An&equivalent&level&of&safety&can&be&obtained&by&terminating&the&

flight&prior&to&30&minutes&or&25%&battery&power,&whichever&occurs&

fi rst.

2. T he&UAS&will¬&be&operated&at&night.&

F. 14&CFR&91.405&(a)&Maintenance&Required

1. This§ion&and&Part&43&apply&only&to&aircraft&with&an&

airworthiness&certificate,&therefore&these§ions&will¬&apply.

2. Maintenance will be acco mplished by PAG pursuant to the

manufacturer’s recommendations.

3.&Maintenance,&preventive&maintenance,&rebuilding,&and&alteration&

will&be&successfully&accomplished&by&trained&personnel.

4.&The&sUAS&shall&be&discrepancy&free&prior&to&initiating&flight.&Price&Aviation&Group

Small%UAS%Petition%for%Exemption 11

5.&If&a&mechanical&issue&arises&the&sUAS&can&land&safely&within&the&“Safe&

Zone.”

G. 14&CFR&91.407&(a)&(1)&

– Operation&After&Maintenance,&Preventive&Maintenance,&

Rebuilding,&or&Alteration

1. This§ion&and&Part&43&apply&only&to&aircraft&with&an&

airworthines s&certificate,&therefore&these§ions&will¬&apply.

H. 14&CFR&91.409&(a)&(1)&and&(2)&

^ Inspections.

1. This§ion&and&Part&43&apply&only&to&aircraft&with&an&

airworthiness&certificate,&therefore&these§ions&will¬&apply.&

I. 14&CFR&91.417(a)&and&(b)&

– Maintenance&Records.

1. This§ion&and&Part&43&apply&only&to&aircraft&with&an&

airworthiness&certificate,&therefore&these§ions&will¬&apply.

D. Reasons why granting this request would be in the public interest.

• PAG&is&a&small&business&that&is&u sing&the&latest& s UAS&technology.&&&

• PAG&will&operate&with&an&equivalent&or&better&level&of&safety.&

• PAG&will&use&a& s UAS&that&has&proven&operational&history.&

• PAG&will&use&available&technology&and&kno wledge&to&ensure&public&safety&

continuously&updating&p rocedures.&&

• PAG&will&only&conduct&flights&where&a&controlled

, sterile&environment&can&be&

assured.&&

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety,

Or How The Exemption Would Provide A Level Of Safety At Least Equal To That

Provided By The Rule From Which PAG Seeks Exemption.

1. PIC and Visual Observer

a. The PIC shall possess at least a private pilot certificate and at least a

current driver ’ s license.

i. The PIC shall also meet the flight review requirementsPrice&Aviation&Group

Small%UAS%Petition%for%Exemption 12

specified in 14 CFR § 61.56 in an aircraft in which the PIC is

rated on their pilot certificate.

ii. The PIC shall be trained in the operation of the specific Make

and Model of the UAS being piloted.

iii. The PIC must have :

1. A minimum of 200 flight cycles and 25 hours of total

time as a sUAS rotorcraft pilot

2. Five hours logged with the make and model utilized

b. The PIC and Visual Observer (V O) will be designated before each

flight

i. Minimum crew for each o peration will consist of the PIC and

the V O.

c. The PIC and V O will always be within visual line of sight (VLOS) of

each other and in direct verbal communication at all times.

d. Safety Briefings prior to each flight:

i. Designated roles of PIC and V O

ii. Risk Management and Mitigation

iii. PIC and VO will inspect site for safety issues.

iv. PIC& will operate the& UAS&with&appropriate&distance&from&non

^ participants in&accordance&with&14&CFR&§ 91.119.

2. SUAS Specifications and Design:

a. All sUAS flown under this exemption shall be less than 55 pounds

including aircraft and payload.

b. The radio frequency spectrum used for operation and control of the

sUAS shall comply with the Federal Communications Commission

(FCC) or other appropriate government oversight agency requirements.

c. Maximum speed shall be no more than 50 knots.

d. The sUAS shall be equ ipped with Inertial Navigation

Sensor(s) (IRS/IRU/Accelerometer).

e. The sUAS shall be equipped with a Compass

(Magnetometer/Heading Source).Price&Aviation&Group

Small%UAS%Petition%for%Exemption 13

f. The sUAS shall be equipped with a Global Positioning System

(GPS) guidance system.

g. The sUAS shall have a return to home feature

3. Maintenance

a. The UAS shall be maintained in accordance with the

manufacturer’s recommendations with appropriate

recordkeeping.

b. The PIC shall perform a preflight inspection of the sUAS, controller,

and ground control station prior to each flight to ensure it is

operational with no discrepancies. If the preflight inspection has any

discrepancies that may affect a safe operation, repairs or maintenance

shall be performed prior to flight. The sUAS will only be operated if it

is free of al l discrepancies.

Any UAS that has undergone maintenance or alterations that affect the

UAS operation or flight characteristics, e.g. replacement of a flight

critical component, must undergo a functional test flight in accordance

with the operator’s manual. The PIC who conducts the functional test

flight must make an entry in the UAS aircraft records of the flight. The

requirements and procedures for a functional test flight and aircraft

record entry must be added to the operator’s manual.

c. PAG shall follow the manufacturer’s sUAS maintenance, overhaul,

replacement, inspection, and life limit requirements. When not

specified a t a minimum, the following shall be included:

i. Actuators / Servos

ii. Powerplant(s) (motors)

iii. Propellers

iv. Electronic speed controller(s)

v. Batteries

vi. Remote controllers and Ground control station

d. All sUAS shall be identified by serial number, registered in accordance

with 14 CFR part 47, and have identification (N

- Number) markings in

accordance with 14 CFR part 45, Subpart C, ex cept with respect to the

size of the markings. Markings shall be as large as practicable.Price&Aviation&Group

Small%UAS%Petition%for%Exemption 14

3. Permissions and Permitting

a. All required permissions and permits shall be obtained from

territorial, state, county or city jurisdictions, including local law

enforcement, or other appropriate governmental agencies.

b. At least three days before a s cheduled operational flight, PAG shall

submit a written Plan of Activities to the local flight standards district

office (FSDO) with jurisdiction over the area of the p roposed flight. The

3

- day notification may be waived with the concurrence of the FSDO.

i. The plan of activities shall include at least the following:

1. Dates and times for all requested flights

2. Name and phone number of the PIC responsible for

operation of the sUAS

3. Make, model, and serial or N

- number of sUAS to be

used

4. Name and certificate number of sUAS PICs involved in

the flight

5. Signature of exemption

- holder or representative

6. A description of the flight activity, including maps or diagrams of any area over which flights will be

conducted, the relationship of that area to any nearby

city, town, etc., and the altitudes essential to accomplish

the operation

c. Documents required under 14 CFR § 91.9 and § 91.203 shall be readily

available to the PIC any time the aircraft is in operation. These

documents shall be made available to the Administrator or any law

enforcement official upon request.

d. PAG shall obtain an Air Traffic Organization (ATO) issued Certificate

of Waiver or Authorization (COA) prior to conducting any operations

under this grant&of&exemption.& Dow&shall&also&request&a&Notice&to&Airman&

(NOTAM)¬ more&than&72&hours&in&advance,&but¬&less&than&48&hours&

prior&to&the operation.

4. Operations

a. The sUAS shall not operate in Class B , C, or D airspace without writtenPrice&Aviation&Group

Small%UAS%Petition%for%Exemption 15

approval from the FAA. The sUAS shall not operate within 5 nautical

miles of the geographic center of a non

- towered airport as denoted on a

current FAA

- published aeronautical chart unless a letter of agreement

with that airport’s management is obtained, and the operation is

conducted in accordance with a NOTAM as required by the operator’s

COA. This letter of agreement with the airport management shall be

made available to the Administrator upon request.

b. Flights shall be conducted under day visual meteorological

conditions (VMC).

i. In addition, the sUAS shall 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.

ii. sUAS operations shall not be conducted during night, as defined in

14 CFR § 1.1.

iii. Flights shall not be conducted under special visual flight

rules (SVFR).

c. Flights shall be operated at an altitude of no more than 400 feet

above ground level (AGL)

.

d. The PIC shall be prohibited from operating the sUAS from any

moving device or vehicle.

e. The sUAS shall be operated within visual line of sight (VLOS) of the

PIC.

i. The PIC shall maintain VLOS without the aid of

telescopes, cameras or other devices.

ii. The PIC will maintain VLOS with the ir own vision, which

includes the use of eyeglasses or corrective lenses

.

f. The sUAS shall remain clear and yield the right of way to manned

operations and activities at all times

g. Prior to any flight operations authorized by this grant of exemption, the

PIC and VO must have successfully completed a qualification process,

as outlined in the operator’s manual. As this is a requirement stipulated

by the operator, the test must be developed and implemented by aPrice&Aviation&Group

Small%UAS%Petition%for%Exemption 16

qualified person designated at the sole discreti on of the operator. A

record of completion of this qualification process must be documented

and made available to the Administrator upon request.

h. The UAS must abort the flight in the event of unpredicted obstacles

or emergencies in accordance with the ope rator’s manual.

i. 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 FAA’s UAS Integration Office

(AFS

- 80) within 24 hours. Accidents must be reported to the National

Transportation Safety Board (NTSB) per instructions contained on the

NTSB Web site: www.ntsb.gov

. Further flight operations may not be

conducted until the incident, accident , or transgression is reviewed by

AFS

- 80 and authorization to resume operations is provided.

5. Flight Time

a. Each sUAS operation shall be completed within 30 minutes flight time

or with 25% battery power remaining, whichever occurs first.

F. Summary for Federal Register publication.

The Rules From Which PAG Seeks Exemption: 14 CFR 61.113(a)

and (b), 14 CFR 91.103, 14 CFR 91.119, 14 CFR 91.121, 14 CFR

91.151(a), 14 CFR 91.405(a), 14 CFR 91.407(a)(1), 14 CFR

91.409(a)(2), 14 CFR 91.417(a) a nd (b)

A. Brief Description Of The Nature Of The Exemption PAG Seeks:

Price Aviation Group (PAG) seeks exemption to operate a UAS under

Section 333 of the FAA Modernization and Reform Act of 2012. This

exemption will allow PAG to operate a UAS for the purposes of aerial

photography and inspection in a controlled, sterile environment. PAG will

be operating a proven airframe to accomplish flights with an equivalent or

better level of safety to manned operations.Price&Aviation&Group

Small%UAS%Petition%for%Exemption 17

CONCLUSIO N

PAG seeks to oper ate sUAS in a manner that will ensure an equivalent level of

safety to the general public. The flights will be conducted to a high standard using

proven technology complying with FAA regulations and the conditions of the requested

exemption.

Specific information on the sUAS is included as an appendix, and any other

information needed to fulfill necessary requirements will be gladly given upon request.

Submitted By:

Christopher Lawler

Price Aviation Group

December 6, 2014