U.S. DepartmentofTransportation DocketManagement System 1200NewJersey Ave., SE Washington, DC 20590. February 22,2016 I 1J

RE: Exemption Request Putsuant to Section 333 of the FAA Modernization and Reform Act of2012, 49 U.S.C. § 44701(f), and Part 11 ofthe Federal Aviation Regulations DearSirorMadam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 ("FMRA") and 14 CFRPart II , R&M Claims Service Inc. is submittingthis Petition and seeks Exemption from the Federal Aviation Regulations as detailed below. ApplicantInformation: Thename ofthe app.Iicant: R&M Claims Service Inc. Theprimary contact for this application, which a copyto me atthe address above, is: BillyRay Payne R&MClaims Service Inc. 90F 117 GlendaTrace, Newnan, Ga. 30265 R&M Clams Service Inc. is a corporation formed under the State laws ofGeorgia on or about April202009, andBillyRay Payne is the owner and PresidentofR&MClaims Service Inc. Pursuantto Section 333 ofthe FMRA, R&M Claims Service Inc. hereby requests a determination bythe Secretary ofTransportation authorizing commercial operations ofUAS for thepurposes ofhigh & steeproofinspections aerial photography & videography, datacollection, aerial windturbine surveillance, aerialpipeline surveillance, commercial videos and otherwork related toaerialphotography intheNAS. R&MClaims Service INC. doesnotintendto usefor closed-set filming. Flightoperationswill utilizethe offthe shetfDJI Phantom 3 Professional families ofunmanned aircraft. ConductofUAoperationswill be with respectto FMRA Section 333(c)andtheUAS "BlanketCOA". Exemption is necessary to effect the determination requested pursuant to FMRA Section 333. The attached documentation includes detailed exemption requests that demonstrate how these exemptions are in thepublic interest and will maintain at least an equal level ofsafetyto existing regulations. Authorizing R&M Claims Service Inc. to conduct commercial UAS operations willFebruary 22, 2016 Page 2ofll

result in less disruptive, safer, and more cost effective solutions than manned aviation equivalents due to the low altitude environment, given the size, speed and inherent risk of traditional commercial helicopter operations. These commercial operations often occur in the unsafe areas ofthe height-velocity diagram requiring special precision and skill. R&M Claims Service Inc. will conductthe commercial UAS operation in a mannerthat will meet, and in many cases exceed, the current level ofsafety ofcommercial helicopter operations. UA that are under 10 lbs., have a low noise signature, and carry no volatile fuel, will limit collateral damage in the event ofcatastrophic failure. The low expense ofoperation compared to costprohibitive manned aviation alternatives allow a greater economic benefit to businesses. For these reasons, granting an exemption under FMRA Section 333(c) is in the public interest. UAS technology used for these commercial purposes benefitthe public interest in the following ways:

• Reduces the collateral damage risks to life and property associated with low altitude helicopter operations in undesirableportions oftheheight-velocity envelope. • Increased economic wellbeing.to local businesses viacostreductions. • Enabling aerial business solutions to be available to a largermarket. • Saferand more thorough inspections ofhigh and steep buildings. • Gaining access to areas thatwere inaccessibleto safely inspectbefore.

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### I. ExemptionsRequested 

### Table ofContents

II. Commercial Operation/Operator III. Unmanned Aircraft System (UAS) IV. UAS Pilot-in-Command (PIC) V. Public Interest VI. Summary VII. ListofAttachments I. Exemptions Requested 

### Pursuant to 14 C.F.R. § 

### 11.81(e), R&M Claims Service Inc. requests exemption from the following regulations:

• 14 C.F.R. Part21 SubpartH- Airworthiness Certificates 

### o Establishes: 

### The procedural requirements for the Issuance of airworthiness certificates as required by 14 C.F.R. § 

### 91.203(a)(l) Given the small size ofthe UA and the safeguards that will be taken as outline below, an exemption from Part21 SubpartH meets the requirements ofan equivalent level ofsafety under Part 11 

### and Section 333 ofthe FMRA with consideration "ofthe size, weight, speed, operational capability, and proximity to airports and populated areas of the particularUAS."

• 14 C.F.R. § 45.23(b)- AircraftMarking and Identification Requirements 

### o When marks include only ·the Roman capital letter "N" and the registration number is displayed on limited, restricted or light-sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light-sport, "experimental," or "provisional," as applicable. R&M Claims Service Inc. will ensure compliance with § 

### 45.29(f) to meet the intent of the regulationby displaying the registration number in the largestpracticable lettering.

• 14 C.F.R. 61.113 (a)(b) and 61.133(a)(1)(ii) and 61.101 - Recreational, Private and CommercialPilot Privilege and Limitations 

### o 14 C.F.R. § 61.113: 

### (a) Except as provided in paragraphs (b) 

### through (g) ofthis section, no person who holds a private pilot certificate may act as pilot in command ofan aircraft that is carrying passengers or property for compensation or hire; normay thatperson, for compensation orhire, act as pilot in command ofFebruary 22,2016 Page 4ofll

an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command ofan aircraft in connectionwith any business oremployment o 14 C.F.R. 

### § 61.133: (a) Privileges

- (1) General. A person who holds a commercial pilot certificate may act as pilot in command ofan aircraft- (ii) For compensation orhire, providedtheperson is qualified in accordance withthis part and withthe applicableparts ofthis chapterthatapplyto the operation. o 14 C.F.R. § 61.101: (a) A person who holds a recreational pilot certificate may not actaspilot in command ofanaircraft: • For compensation orhire; • In furtherance ofabusiness; UA operations will employ a PIC who holds, at a minimum, a recreational or sport pilot certificate ofany category orclass and a valid driver's license.

• 14C.F.R. 91.7(a)- CivilAircraftAirworthiness o Noperson may operate a civil aircraftunless itis in anairworthy condition. The PIC will conduct daily pre and post flight inspections in accordance with manufactures maintenance manual(s) and guidance. During flight, the PIC will adhere to § 91.7(b) and abort air operations immediately upon identification of an in-flight emergency or other unsafe condition. By complying with procedures outlined by the manufacturer, an equivalentlevel ofsafety will be achieved. ·

• 14 C.F.R. 91.9(b) Civil aircraftflight manual, marking, and placard requirements o (b)(2) prohibits operation ofU.S.-registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combinationthereof. By keeping all operating documents, manuals, authorizations and exemptions in a binder co-located withthe GCS, R&M Claims Service Inc. meetthe intentofthe regulations and therefore achieve an equivalent level ofsafety.

• 14 C.F.R. 91.109(a)- FlightInstruction o No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircrafthas fully functioning dual controls. The majority of sUAS by design are developed with single operational control through the use ofpre-determined GPS enabled waypoints programmed before orduring flight in addition to the use ofa single hand held transmitter or control station controlled by the PIC. The design does not allow for dual controls during flight training and therefore the exemption is requestedto train operators, build experience, and maintain proficiency. An equal level ofsafety will be achieved by conducting all training in sterile environments. Training sessions will be accomplished separately from flights conducted for compensation orhire.February 22,2016 Page 5ofl1

• 14 C.F.R. 91.119 (c)- Minimum SafeAltitudes 

### o Except when necessary for takeoffor landing, no person may operate an aircraft below the following altitudes: (b) Over any congested area of a city, town, or settlement, or over any open air assembly ofpersons, an altitude of 1,000 feet above the highest obstacle within a horizontal ntdius of2,000 feet ofthe 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 closer than 500 feet to any person, vessel, vehicle, or structure. (d) Helicopters, powered parachutes, arid weight-shift-control aircraft. If the operation is conducted without hazard to persons orproperty on the surface- (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) ofthis section, provided each person operating the helicopter complies with any routes oraltitudes specifically prescribed for helicopters by the FAA. Commercial UAS operations will be conducted at or below the maximum altitude authorized by COA. Given the size, weight and lack offuel; combined with operation limitations listed below, the operation will be conducted with a greater level of safety than exists with currentmanned aviation operations.

• 14C.F.R.91.121- AltimeterSettings o Each person operating an aircraft shall maintain the cruising altitude or flight level ofthat aircraft, as the case may be, by reference to an altimeter that is set, whenoperating

... SUAS are equipped with Global Positioning System (GPS), which provide altitude and geo-location data to the operator without utilizing an altimeter. Due to this fact, an exemption is required. GPS are precise within a few feet and combined with fail-safes and a visual observerthe operation will meet an equivalent level ofsafety.

• 14 C.F.R.91.15l(a)- FuelRequirementsforFlightin VFRConditions o 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 afterthat for at least 30 minutes; This regulation is written based on the capabilities ofa traditional aircraft, which have flight times ofseveral hours or greater; therefore, with the majority ofsUAS which have flight times ofonly an hour or less, this regulation would effectively deny the ability of theair vehicleto operate. · The PIC will achieve an equivalent level ofsafety by complying with all manufacturer guidelines andthe 3D Robotics and Dlllowbattery failsafe systems.February 22, 2016 Page 6ofll



### • 14 C.F.R. 91.215(b)- ATC Transponder and Altitude Reporting Equipment and Use. o All airspace. Unless otherwise authorized or directed by ATC, no person may operate an aircraft in the airspace described in paragraphs (b)(l) through (b)(S) of this section, unless that aircraft is equipped with an operable coded radar beacon transponder having either Mode 3/A 4096 code capability, replying to Mode 3/A interrogations with the code specified by ATC, or a Mode S capability, replying to Mode 3/A interrogations with the code specified by ATC and intermode and Mode S interrogations in accordance with the applicable provisions specified in TSO C-112, and that aircraft is equipped with automatic pressure altitude reporting equipment having a Mode C capability that automatically replies to Mode C interrogations by transmitting pressure altitude information in 100-foot increments. Thisrequirement applies- (1) All aircraft. InClass A, ClassB, and Class C airspace areas; (2) All aircraft. In all airspace within 30 nautical miles of an airport listed in appendixD, section l ofthispart from the surface upwardto 10,000 feet MSL; (3) Notwithstanding paragraph (b)(2) ofthis section, any aircraft which was not originally certificated with an engine-driven electrical system or which has not subsequently been certified with such a system installed, balloon or glider may conduct operations in the airspace within 30 nautical miles ofan airport listed in appendix D, section 1ofthispartprovided such operations are conducted- (i) Outside any ClassA, ClassB, orClass C airspace area; and (ii) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport or I0,000 feet MSL, whicheveris lower; and (4) All aircraft in all airspace above the ceiling and within the lateral boundaries ofa Class B or Class C airspace area designated for an airport upward to 10,000 feet MSL; and (5) All aircraft except any aircraft which was not originally certificated with an engine-driven electrical system or which has not subsequently been certified with such a system installed, balloon, or glider- (i) In all airspace ofthe 48 contiguous states and the District ofColumbia at and above I0,000 feet MSL, excludingthe airspace at and below 2,500 feet above the surface; andFebruary 22, 2016 

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(ii) In 

### the airspace from the surface to I0,000 feet MSL within a 10-nautical-mile radius ofany airport listed in appendix D, section 2 ofthis part, excluding the airspace below 1,200 feet outside ofthe lateral boundaries ofthe surface area of the airspace designated for that airport. The sUAS to be used in the proposed operation does not come equipped with a transponder. No transponder exists for the sUAS, which can be installed. The petitioner requests relieffrom the exemption to the extent required to operate in areas in which a transponderisrequired accordingthe applicableregulations in thispart. The PIC will achieve an equivalent level of safety by complying with all provisions of the COA under which operations are to be conducted. By issuing appropriate NOTAMS and prior ATO coordination, an equivalent level of safety can be achieved as other manned aircraft, which receive authorization to fly in airspace where a transponder is required but not operable. In

### orderto give propernotice to the ATO, the PIC will comply with the provisions of91.215(d)(3). The sUAS flown under this exemption will comply with all altitude limits and airport standoffdistances required by COA, which mitigate hazardsto aircraft controlled by the ATO in congested airspace.

• 14 C.F.R. 91.405(a), 91.407(a)(l), 91.409(a)(2) and 91.417(a) & 

### (b)

- Maintenance Inspections o 91.405(a) States: Each owner or operator of an aircraft-{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) ofthis section, have discrepancies repaired asprescribed in part43 ofthis chapter o 91.407(a)(l) States: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-{I) It

### has been approved for return to service by a person authorized under § 

### 43.7 ofthis chapter o 91.409(a)(2) States: (a) Except as provided in paragraph (c) ofthis section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had-{2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 ofthis chapter. No inspection performed underparagraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an "annual" inspection in the required maintenance records. o 91.417(a) & 

### (b) States: (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) 

### ofthis section: (paragraphs 1 (i -iii), 

### 2 (i vi)); (b) The owner or operator shall retain the following records for theperiods prescribed: (paragraphs I 3)February22, 2016 Page 9ofll

III. Unmanned AircraftSystem R&M Claims Service Inc. seeks exemption to operate DJI Phantom 3 Professional. Other UAS types may be requested in future amendments. The DJI Phantom 3 Professional are the primary aircraft in ouroperation for which we seek exemption The UA will be flown via a combination ofRC control and tablet GCS. UA types are GPS equipped, multirotor helicopters. Quad-copter type rotorcraft utilizing four motors. Lithium-polymerbatteriespowerthe UA. TheUA also has several fail-safes for loss ofRC signal, loss ofGPS, and lowbattery as outlined in the respective Operation Manuals. The UA display visual and emit an audible low battery alerts at which time the UA will automatically engage the landing sequence. Based upon those safeguards, I request exemption from Section 91.15l(b) Fuel requirements for flight in VFR conditions. Given the size, weight, speed, and controlled operating area associated with the UA to be utilized, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) is requested. Exemption is sought from § 45.23 Marking of the aircraft. The 

### VA will display the registration numberin the largestpracticable lettering. R&M Claims Service Inc. seeks to be exempt from § 91.405(a), 91.407(a)(l), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections will be conducted according to operations manual and prudent judgment as previously outlined to determine the integrity and safety ofthe UA and associated equipment. Further, reliefis required from 91.7(a), which prohibits the operation ofan aircraft without an airworthiness certificate and 9L9(b) (2) requiring an approved flight manual in the aircraft. The UA will not be operating with an airworthiness certificate therefore, this would be inappropriate. The 

### VAS are too small to carry the operating documents so an equivalent amount ofsafety can be achieved through keepingthe operating documents and manuals at the GCS. IV. UAS Pilot in Command (PIC) Under part§ 61, recreational, sport and private pilots are limited to non-commercial operations, howeverR&M Claims Service Inc. can ensure UA operations will achieve an equivalent level of safety as current regulation because UA do not carry any pilots or passengers. A commercial pilot certificate will not ensure RC piloting ability, as the psychomotor skills are different. The inherent risks ofoperating a UAS are far less than in the commercial activities outlined in 14 CFR part 61, et seq., thus exemption is requested from§ 61.101 Recreational Pilot Privileges and Limitations. PICs will maintain recent flight experience on the UAS. Training and experience flights will be conducted separate from commercial operations. V. Public Interest Given the above stated evidence, procedures, and precautions operating 

### VAS commercially for the purposes of aerial photography & videography, data collection, aerial wind turbine surveillance, aerial pipeline surveillance, commercial videos and other work related to aerial photography will ultimately be in the public interest. These operations, when executed withFebruary 22, 2016 Page 10 ofll
prudence, will exceed the current level ofsafety as the regulations from which exemption is sought. UA operations will allow greater access to commercial aerial services that were not previously economically feasible for many firms. This will provide a much needed economic uplift to the community and hence the public. UA operations are associated with less risk of collateral damage to persons and property while limiting disruptive noise pollution associated with low altitude aviation operations. VI. Summary Pursuantto Section 333 ofPL 112-95 commonly known asthe "FAAModernization and Reform Act of2012",R&MClaims ServiceInc., hereby applies for authorizationtoconduct commercial unmanned aerial systems (UAS) operations for the purposes ofsteep and high roofinspections, aerial photography & videography, data collection, aerial wind turbine surveillance, aerial pipeline surveillance, commercial videos and other work related to aerial photography listings Rules for which exemption is sought: 

## • 14 C.F.R. Part21 Subpart H 

# • 14 C.F.R. §45.23(b) 

# • 14 C.F.R. §61.101,61.113 and 61.133(a)(l)(ii) 

# • 14 C.P.R.§ 91.7(a) 

## • 14 C.F.R. 91.9(b) 

## • 14 C.F.R. § 91.103 

# • 14 C.P.R.§ 91.109(a) 

# • 14 C.F.R. §91.119 

# • 14 C.P.R.§ 91.121 

## • 14 C.F.R. §91.151(a) 

## • 14 C.P.R. §91.215(b) 

# • 14 C.F.R. §91.405(a) 

# • 14 C.F.R. § 91.407(a)(l) 

# • 14 C.F.R. § 91.409(a)(2) 

# • 14 C.P.R.§ 91.417(a) & (b)

VII .Attachments: 1. Specific UAV manuals • DJIPhantom 3 UserManual • DJIPhantom 3 ChargingHubUserManual • DJIPhantom 3 Howto UpdateFirmware • DJIProfessional ReleaseNote Thank you for yourpromptattention and consideration. Ourcompany and its clients are committed to safe UAS operation and ambassadors. Please do nothesitateto contactme directly with any questions orconcerns at 678-787-8035.February 22,2016 Pagellofll

ES/cam 

### Enclosures

### V~J.Jours, .

# If&~~~ Inc.

Billy RayPayne R&MClaims Service Inc. 90F 117 Glenda Trace, Newnan Ga30265