Flightline Geographics LLC 150 Sunset Ridge, Dripping Springs, Texas 78620 www.flightlinegeographics.com
512.264.3246 May 14, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

Re: Flightline Geographics LLC Petition for Section 333 Exemption for RPA Technologies RQ

- 265

Dear Sir or Madam,

Pursuant to Section 3 33 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14
C.F.R. Part 11, Flightline Geographics LLC (Flightline) is petitioning the Federal Aviation Administration (FAA) for an exemption from the Federal Aviation Regulations (FARs) requested
below concerning small unmanned aerial systems (UAS). Section 333 of the FMRA promotes UAS integration into the national airspace by granting the FAA authority to allow for the safe operation of certain UAS within the national airspace.

Flightline specializes in aerial data collection for Geographic Information Systems (GIS). Flightline is the U.S. reseller for RPA Technologies Ltd (RPA) RQ

- 265 small UAS. Our team has attended factory training by RPA and continues to practice missions through the RQ

- 265 X

- Planes Simulator plug

- in, which provides a realistic mission planning and execution environment for rehearsing missions and gaining additional experience.

Flightline employs flight crews consisting of factory

- trained or factory

- supplied UAS pilots, FAA

licensed p ilots, visual observers and post

- processing GIS technicians. Flightline has participated in several government and university

- run research projects under COAs in Texas since 2012, by providing aerial image capture consulting and processing. In addition, Fl ightline is aligned with the Lone Star UAS Center for Excellence and Innovation at Texas A&M University and plans to perform safe and controlled UAS operational testing for GIS applications under a variety of conditions and is willing to share the flight d ata with the FAA.

Flightline proposes to operate small UAS subject to restrictions and conditions that will ensure an equivalent level of safety and that are at least as stringent as those that FAA has found to be acceptable in its most recent grants of p etitions under Section 333, including numbers 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 Labs, Inc. ( see Docke t No.FAA

− 2014

− 0642). Further, this petition raises no national security or privacy concerns. Flightline therefore respectfully submits that prompt grant of this petition is warranted.

As a GIS data content provider, Flightline will capture Remote Sensing data in a safe and effective manner for multiple industries and governmental uses. For this reason, Flightline will use the RPA Technologies RQ

- 265 with off

- the

- shelf Digital SLR cameras and other similar lightweight sensor technologies, as they become ava ilable. This aircraft weighs less than 55 pounds and has been operated safely for several years with the approval of civil aviation authorities in several other countries including New Zealand, Australia, Canada and others. This aircraft, due to its advanc ed safety features, including the MILSPEC autopilot and emergencyparachute landing mode, has even been approved for operation over urban areas in New Zealand by their CAA. The detailed specifications of the aircraft are listed in a section below.

Flightli ne will use experienced pilots and visual observers (VOs) for all of its UAS operations. All pilots and VOs will receive factory UAS training and flight hours in accordance with manufacturer operational manuals before approval to fly is given.

Flightline i s requesting this exemption in order to provide services for many industries, including
but not limited to:



### 1. Mapping and GIS

– High definition image data for small

- scale project locations that are not currently cost

- effective or safe for manned capture (env ironmental studies, utilities, energy exploration, emergency management, wetlands delineation, storm damage
assessment, pipeline inspection, etc.)



### 2. Government Agencies

– Federal, State and Local (Local governments with small scale project areas and limited budgets will be better able to afford UAS services, as opposed
to manned flights)



### 3. Engineering

– Site assessment, construction, documentation



### 4. Insurance

– Damage assessment and verification



### 5. Agriculture

– NDVI processing of aerial imagery for vegetative healt h and general range management

Flightline is requesting to use the UAS in rural locations only for GIS data collection for a variety of end user customers. These project locations will fall outside of heavily populated areas when plotted on VFR Sectional A eronautical Charts and other map

- based GIS sources and will not be within five (5) miles of any airport (unless FAA has approved such operations and Flightline has a written agreement with the airport manager).

Flightline’s initial work will take place nea r its main office in Dripping Springs, TX. Projects will be pursued initially within Texas and surrounding states, and may expand to other locations that are economically suitable.

Flightline is submitting the manufacturer’s Flight Operations Manual, Main tenance Manual and sample SOP Flight Ops Checklist confidentially pursuant to 14 CFR Section 11.35(b). The Manuals contain confidential, proprietary and commercially sensitive information that has not
been made available to the public and that is protected under the Freedom of Information Act, 5
U.S.C. § 552, et seq.

Petitioner Name and Address: Flightline Geographics LLC 150 Sunset Ridge Dripping Springs, TX 78620 Devon Humphrey

– CEO devon@flightlinegeographics.comExemptions Requested :

Flightline Geo graphics LLC is requesting this waiver as it applies to the following FARs:

• 14 CFR Section 61.113 (a) and (b): Private pilot privileges and limitations

• 14 CFR Section 61.23 (a) and (c): Operation with a driver’s license in lieu of FAA medical
certificate

• 1 4 CFR Section 61.101 (e)(4) and (5): Allow private pilot certificate holder to operate UAS for compensation

• 14 CFR Section 61.113(a): Allow sport pilot certificate holder to operate UAS for compensation

• 14 CFR Section 61.315(a): Allowing holder of sport p ilot certificate to serve as PIC of UAS

• 14 CFR Section 91.7(a): Civil aircraft airworthiness

• 14 CFR Section 91.119(c): Minimum altitude requirements

• 14 CFR Section 91.121: Altimeter requirements

• 14 CFR Section 91.151(a)(1): Fuel requirements

• 14 CFR Section 91.405(a): Maintenance requirements

• 14 CFR Section 91.407(a): Maintenance requirements

• 14 CFR Section 91.409(a)(1)(2): Inspection frequency

• 14 CFR Section 91.417(a)(b): Maintenance records

Flightline’s H istory

Flightline has been processing and deliverin g GIS data in the form of aerial visual intelligence from manned and unmanned platforms since 2012. Flightline has participated on previous projects for Federal Agencies and major Public Universities under FAA COAs. Flightline’s role has been as a GIS subj ect matter expert and data processing service provider working with UAS data for agricultural and emergency management applications. This has provided exposure to and participation in professionally

- run and safe UAS flight operations since 2012. With the g rowth of the UAS industry and recent commercial exemptions that have been granted, Flightline is petitioning to safely and legally operate its own UAS in the National Airspace.

Flightline is the U.S. reseller for the RQ

- 265 UAS manufactured in New Zealand. This aircraft has been accepted by civil aviation authorities in New Zealand, Australia, Canada and many other modern countries. The aircraft can carry true color (RGB), infrared (IR) and other lightweight sensors for specialized imagery applications for GIS and mapping, including agriculture, engineering, environmental and energy transmission line right

- of

- way monitoring. The system is
hand

- launched and parachute

- landed and its safety features are recognized by civil aviation
authorities in the countries listed above.

The RQ

- 265 includes a MILSPEC DTA autopilot which incorporates many recognized safety features, including automated flight termination system by parachute under a variety of faultconditions, maintenance of a Minimum Safe Altitude (MSA) and terrain collision avoidance measures using the world

- wide SRTM elevation model. While the system is designed to be able to operate beyond line

- of

- sight, Flightline will not operate in this mode, always remaining within
line

- of

- sight of the PIC and VO.

Sum mary of operations

1. All flights will be conducted in accordance with the manufacturer’s Flight Operations Manual (FOM)

, following Visual Flight Rules (VFR).

2. The UAS with payload will weigh less than 55 pounds.
3. All flights will include a Pilot in Command (PI C) and Visual Observer (VO). Flights will be operated within visual line of sight of the PIC and VO. The PIC and VO will be able to communicate verbally at all times.

4. The PIC and VO will have manufacturer’s training and flight hours with the RQ

- 265 in

acco rdance with the manufacturer’s requirements.

5. The PIC must hold at least an FAA Sport Pilot Certificate. The PIC must also hold a current valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or th e Federal government.

6. Prior to each flight, the PIC will inspect the UAS to confirm that it meets manufacturer specifications for safe flight. The UAS ground control system software requires that all items on the pre

- flight checklist be completed prior to initiating a launch.

7. After a maintenance event involving a critical component of the UAS, a test flight will be performed and logged in the aircraft maintenance logs.

8. A pre

- flight briefing will be conducted describing the planned UAS mission prior to each flight. This pre

- flight briefing is delivered by the PIC and is mandatory for all VOs.

9. All flights will be conducted within a defined “sterile area” containing a security perimeter for the flight operations area. These areas, along with any identified “U AS no fly zones” around tall structures or elevation features will be clearly identified on the flight ground control station computer, where the location and status of the aircraft is also monitored in
real time.

10. All required permissions and notifications to federal, state and local governments, including law enforcement, fire or other appropriate governmental agencies.

11. Written or verbal permission from the property owner will be obtained.

12. In accordance to the manufacturer’s FOM, both primary and alternat e landing areas will be designated before any UAS flight is attempted.

13. The UAS will not be flown at night or when weather conditions may prevent a visual observation of the vehicle throughout the duration of the flight.

14. Maximum flight time will be less tha n 90 minutes per the manufacturer’s recommendation. The UAS autopilot monitors battery charge in real time and will enter return mode and land at the pre

- designated landing location with 20% battery remaining.

15. Airspeed will not exceed 87 knots

16. Flights will be operated at an altitude of 400 feet AGL or less and more than 100 feet
above any building or structure to be imaged or inspected.

17. The UAS will remain clear and yield to all manned aircraft.

18. If GPS signal is lost but communications link remains, the PIC will manually return the
aircraft to one of the pre

- determined landing zones or perform an immediate landing as per the manufacturer’s FOM.

19. In the unlikely event of a lost link/communication loss, the RQ

- 265 is preprogrammed to return to a pre

- designated landing location within the security perimeter and to perform a safe automated landing procedure by parachute.20. Flightline will follow all manufacturer maintenance and inspection procedures, schedules and documents for the UA and log each event in the airc raft maintenance logs in
accordance with the manufacturer’s FOM.

Aircraft to be Used

Flightline Geographics will be operating the RQ

- 265 UAS from RPA Technologies Ltd. The RQ

265 is an all

- electric aircraft that provides precision 3D mapping and real

- time thermal infrared
and full motion video capabilities. The system is hand

- launched and parachute landed. A detailed

pre

- flight procedure is prescribed by the manufacturer in its FOM and must be confirmed prior to any flight within the flight control softwar e. (A launch will not be allowed by the software if any items from the pre

- flight checklist are missed.) The RQ

- 265 is the 2015 version of the RQ

- 84Z,
which has a proven safety record in several countries throughout the modern world, including New Zealand, Australia, Canada, Mexico, Mongolia, Turkey, among others.

The RQ

- 265 is landed by parachute and provides an excellent platform for aerial sensing operations. The parachute is both an emergency and automated primary landing method for the
RQ

- 265. A skid landing is also an option, though not the preferred method. The RQ

- 265 is well suited for collection of larger project areas (i.e. approximately one square mile, or slightly more, per flight) due to its long endurance.

RPA RQ

- 265 Specifications include:

• W ing Span: 102”

• Length: 43.2”

• Weight 11 lbs with standard camera payload

• Top speed: 45 knots

• Cruise Speed: 32 knots

• Endurance: 1.5 hours

Extent of relief

Flightline seeks an exemption from several provisions of 14 CFR Part 91 as part of the UAS exemption. The following list details the exemptions requested and the mitigation procedures that will ensure an equivalent level of safety to the public and the national airspace. FAA has granted similar exemptions to those requested below in, for example, Exemption Nos. 11136, 11138,
11150 and 11153.

14 CFR Section 61.113 (a) and (b)

Section 61.113 (a & b) limits private pilots to non

- commercial flight operations. S ince Flightline’s primary business is commercial GIS data acquisition during flight, an exemption from this section is necessary.

Equivalent Level of Safety Because the UAS does not carry crew or persons, the equivalent level of safety can be achieved by pilots who have completed the Manufacturer’s required training course and who hold a minimum of a Sport Pilot certificate. The FAA itself, in Exemption No. 11462, concluded that Sport Pilot certificate will ensure that the PIC has proper knowledge and training. Flightline agrees that the awareness of airspace restrictions, communication with ATC and situati onal awareness concerns to safely operate within the National Airspace are satisfied by a minimum of a Sport Pilot certificate.The RQ

- 265 UAS is remotely piloted with no passengers or crew on board and the MILSPEC autopilot and parachute primary and eme rgency landing procedures provide an added measure of safety against human error in flying the UAS. For these reasons, Flightline is certain that an equivalent level of safety will be maintained with this exemption.

14 CFR Section 61.23(a)&(c), 61.101(e)(4 )&(5), 61.315(a): Who can Operate a UAS commercially

The FAA has previously allowed operation with a federal or state

- issued driver’s license in lieu of
an FAA

- medical certificate, to allow the holder of a private pilot certificate to operate a UAS for

com pensation, and to allow holder of a sport pilot certificate to serve as PIC of a UAS.

Equivalent Level of Safety

It has been previously recognized that the holder of a minimum of a Sport Pilot Certificate can provide an equivalent level of safety to a Pri vate Pilot certificate.

Flightline is requesting exemption to the above regulations as only holders of a minimum of a sport pilot certificate will be operating our UAS.

14 CFR Section 91.7(a): Airworthiness

Section 91.7(a) requires that no person may opera te a civil aircraft unless it is in an airworthy condition. To the extent that this regulation would require an airworthiness certificate for the aircraft, Flightline requests an exemption.

Equivalent Level of Safety

All UAS operated by Flightline will be under 55 pounds, including payload, and will operate in a defined area made known to local ATC. Furthermore, the vehicles Flightline will operate do not carry personnel, explosive materials or flammable liquid fuels or other potentially hazardous materia ls. The vehicles to be used will be maintained to the strict
tolerances of Flightline’s Director of Maintenance and the guidelines set out in the operations manuals of the manufacturer ‘s Flight Operations Manual (FOM). The RQ

- 265 and its predecessor, the RQ

- 84Z have many thousands of successful flight hours logged.

Thi s UAS, piloted by Flightline’s pilots, do es not represent a risk to the national airspace
or the public.

14 CFR Section 91.119(c): Minimum altitude requirements

Flightline requests an ex emption from the minimum safe altitude requirements specified in 14
CFR 91.119(c). The altitude required by this section is 500 feet above the surface and persons, vehicles, etc. Flightline plans to operate the UAS at or below 400 feet AGL (but not less th an 100
feet above structures, buildings, vehicles, etc.) in order to properly collect imagery data and to avoid entering the national airspace at an altitude that could possibly conflict with manned aircraft.

Equivalent Level of Safety

As explained in thi s document, the manufacturer’s FOM

, every precaution will be taken to assure that the UAS is operating safely with existing air traffic and poses no risk to ground
assets and persons.14 CFR Section 91.121: Altimeter requirements

This section requires th at the pilot of the aircraft use an altimeter on board the aircraft to determine altitude. The altimeter must be set based on the barometric pressure of the departing airport and airports in route. Petitioner seeks an exemption from 14 CFR Part 91.121 as G PS is instead used by the autopilot to provide altitude measurements in feet AGL.

Equivalent Level of Safety

As part of the flight monitoring software of each UAS, the GPS altitude is displayed within the Ground Control Station display and audible feedb ack prompts will be given during flight when altitude approaches 400 feet. Pre

- flight checks will confirm the correlation of
the GPS altitude of the location of the flight compared to the flight plan to confirm the plan ’ s accuracy and make any necessary ch anges (including the abort of the mission). As an additional safety measure, the manufacturer’s FOM and flight control software both require a minimum of 7 GPS satellites to be in view in order to proceed with pre

- flight and launch, ensuring a valid GPS lo cation and altitude.

14 CFR Section 91.151: Fuel requirements

Petitioner requests exemption from 14 CFR Part 91.151 which states: “(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind
and forecast weather conditio ns) 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”

The remaining section does not apply, as the UAS will not be flown at night. Since most UAS flights will be 60

- 90 minutes in duration, another method of determining safe flight limits must be
considered.

Equivalent Level of Safety

Flightline and the flight control software will require that in order for the pilot to take off (initiate a miss ion), the battery charge displayed by the system must be a full charge (>97%) and the aircraft will end its mission such that the total flight time does not exceed 90 minutes, in accordance with the manufac turer’s recommendation. This will ensure that
the UAS lands safely at one of the designated landing areas before battery life becomes
critical or unstable. The flight control software includes battery monitoring and reserve charge features, ensuring a safe return with sufficient battery to make a parachut e landing. There is a separate power supply that provides power to the parachute

- based Flight Termination System, even if main power is lost. Sufficient reserve battery power is always maintained as recommended by the manufacturer and is monitored by the f light control system at the Ground Control Station. Audible warnings are issued to the PIC as the lower limit of operation is reached.14 CFR Section 91.405, 14 CFR Section 91.407, 14 CFR Section 91.409, 14 CFR Section

91.417: Maintenance Reporting and Ma intenance Inspection frequency

Petitioner seeks an exemption from the above regulations and their references to 14 CFR Part

43. 14 CFR 91.405(a) states that each owner or operator of an aircraft “ Shall have that aircraft inspected as prescribed in subpar t E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43
of this chapter ”.

Since the UAS will not have an airworthiness certification, these regulati ons will not apply to these aircraft. Additionally, the nature of the vehicles is that of easily replaced off

- the

- shelf parts and a
much smaller number of parts that can be replaced

– making inspection schedules less fixed and
field repairs possible.

Equi valent Level of Safety

Using the manufacturer ’s FOM and maintenance manual, an inspection and preventative

maintenance schedule will be followed for the RQ

- 265. Because the UAS is dismantled for storage and shipment after each flight, a thorough inspectio n will be performed after the reassembly of the vehicle and before each flight. The maintenance will be overseen by Flightline’s Director of Maintenance (DOM) who will ensure that the inspections and preventative maintenance are performed and logged and si gned in the UAS log book. It is Flightline’s intention to keep maintenance logs for each of its UAS, as prescribed by the manufacturer, and to make these available to FAA inspection at any time. The DOM will ensure that any PIC or VO is able to perform fie ld repairs and replacements as necessary. All field repairs and replacements will be correctly logged and signed on site by the PIC.

Public Interest

Granting Flightline this waiver is in the public interest for several reasons. The aerial imagery and

geos patial data add to the public’s benefit including agricultural analysis, environmental studies, construction monitoring, safe and rapid disaster response, damage assessment, emergency response planning and a wide range of other GIS uses to be determined by the customers. Many of these applications are not cost

- effectively or safely performed by manned aircraft and the lower cost and more rapid turn

- around times for the data and imagery means that customers are more able to utilize this capability for projec ts in the public interest and on a more frequent basis.

Flightline’s use of UAS will decrease the need for manned aircraft in the air and thus reduce pollution, airspace congestion, and risk to crews and others. Flightline recognizes and supports
the need to establish standards for UAS operators, which will safeguard the NAS. Flightline will
offer and conduct UAS operations using skilled professionals who will adhere to the required safety standards.

The UAS operated by Flightline will be under 55 pounds i ncluding payload, will operate in a
defined area made known to local ATC, and will not carry personnel, explosive materials or flammable liquid fuels or other potentially hazardous materials

– only cameras and related imaging sensors.Summary to be Publis hed in the Federal Register (if necessary)
Petitioner: Flightline Geographics LLC

Sections of 14 CFR Affected: 14 CFR Section 61.113, 14 CFR Section 91.7, 14 CFR Section 91.119, 14 CFR Section 91.121,14 CFR Section 91.151, 14 CFR Section 91.405, 14 CFR
Section 91.407, 14 CFR Section 91.409, 14 CFR Section 91.417.

Description of Relief Sought: Petitioner seeks relief from the requirements of 14 CFR Section

61.113, 14 CFR Section 91.7, 14 CFR Section 91.119, 14 CFR Section 91.121,14 CFR Section

91.151, 14 CFR Section 91.405, 14 CFR Section 91.407, 14 CFR Section 91.409 and 14 CFR

Section 91.417 in order to conduct aerial data collection missions for GIS using small
unmanned aerial systems for commercial uses in the service of many business and
governmental sectors.

Conclusion Flightline Geographics LLC believes that the criteria provided in Sect i on 333 of the FMRA

reg a r ding size, weight, speed, operating capabilities, proxim i ty to airports and populated

areas, operat i on within visual line of s i ght, and nat ional security have been sat i sfied. Flightline's commitment to follow these criteria in a professional manner should justify the granting of this exemption request. Please contact Devon Humphrey at Flightline Geographics LLC with any questions or for mor e information.

Devon Humphrey Flightline Geographics LLC 150 Sunset Ridge Dripping Springs, TX 78620

512

- 264

- 3246 devon@flightlinegeographics.com

Attachments: RPA RQ

- 265 Flight Operations Manual ( including sample SOPs, flight logs and check lists), Flight Operations Checklist and Maintenance Manual. These documents are submitted as Confidential Documents under 14 CFR 11.35(b) and exempt from disclosure under the Freedom of Information Act.