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

Re: Exemption Request Section 333 ofthe FAA Reform Act
Dear Sir/Madam, This petition is being submitted on our own behalfwithout legal counsel or consulting services. Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act), and 14 C.F.R. Part 11, AEROWAZE, LLC a Minnesota based limited 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 belowto allow operation ofour sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and underthe conditions outlined herein or as may be established by the FAA as required by Section 333. The requested exemption would permitAEROWAZE, LLC to pursue its commercial interests in providing services to consumers interested aerial data capture using a small advanced sUAS in the following areas:

• Aerial Mappingfor engineering services
• Infrastructure Survey • Agricultural Surveying
• Aerial Photography (notincluding closed-set filming)
• Aerial Videography • Real Estate Photography • Product Demonstrations AEROWAZE states that all sUAS flights that will occur over private or contr.olled access property will do so with the property owner's prior consent and knowledge and that only people who have consented or otherwise have agreed to be in the area where photography and videography will take place will be captured. Additionally, AEROWAZE pilots hold FAA Private Pilot Licenses with Class Ill Medical Certificates and if observers are not qualified pilots, they will be trained by AEROWAZE pilots to understand the proper roles ofan observer, communication procedures, propervisual scan techniques, operations at nontowered airports, and appropriate sections ofthe Aeronautical Information Manual. Regulations from which the exemption is requested: 14 C.F.R. Part 21, 14 C.F.R. 45.27, 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), 14C.F.R. 91.105, 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), 14C.F.R. 91.205 (b), 14 C.F.R. 91.215, and 14 C.F.R. (91.401- 91.417) 

## Unmanned Aircraft System

sUAS are afeasible method to obtain information ofagricultural cropland to determine optimum inputs that result in cost savings to farmers, yield security, and reduce environmental impact ofexcess fertilizers and chemicals in the soil. They have proven to save lives in dangerous situations such as flarestack inspections and search-and-rescue missions. We are petitioning for exemption to enable AEROWAZE to operate aTarot 680 Pro Hex rotor equipped with athree-axis gimbaled camera and control with a 3DRobitics Pixhawk flight controller, a DJI Inspire 1 multi-rotor equipped with athree-axis gimbaled camera, a Skywalker X-8 single wing airplane also with the 3DRobitcs Flight controller, safety parachute and a multi-camera payload, Trimble Gatewing UX5 system and Topcon eBee

. These sUAS all weigh less than 25 lbs, have a built-in capability to limitthe height itflies above the ground, to limitthe radius ofthe distance itflies from the operator and includes a no fly zone feature. Each system also has the failsafe function ofthe autopilot system, which means when the communication between the main controller and the transmitter is lost; the system will automatically trigger Return to Home and will land safely. The above specifications meet standards listed below, some derived in accordance with the Model Aircraft Operating Standards:

• The petitionerwill only operate its sUAS in line ofsight ofa pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas within the sterile area described in the operator's manual. Such operations will insure that the sUAS will"not create a hazard to users ofthe national airspace system orthe public." • Under new FAA policy, "the FAA will grant a Certificate ofWaiver orAuthorization (COA) for flights at or below 200 feet to any UAS operatorwith a Section 333 exemption for aircraftthat weigh less than 55 pounds, operate during daytime Visual Flight Rules (VFR) conditions, operate within visual line ofsight (VLOS) ofthe pilots, and stay certain distances away from airports or heliports: • 5 nautical miles (NM) from an airport having an operational control tower; or • 3 NM from an airport with a published instrument flight procedure, but not an operational tower; or • 2 NM from an airportwithout a published instrumentflight procedure or an operational tower; or • 2 NM from a heliport with a published instrument flight procedure" • Flights requiring an additional COA for operations outside the above parameters will be coordinated with the FAA. • Maximum flight time for each operational flight will be 60 minutes. • Flights will be terminated at 25% battery power reserve should that occur priorto the 60-minute limit.• The sUA V will be programmed so that itwill not be operated at an altitude of no more than 400 feet AGL, unless otherwise approved by the FAA. • Minimum crew for each operation will consist ofthe sUAS Pilot and the Visual Observer. • The sUAS PIC's (Pilot in Command) will be an FAA licensed airman holding at a minimum an FAA Private Pilot Certificate and Third Class FAA Medical Certificate. • The sUAS operated by the petitionerweighs less than 55 pounds, including the payload (i.e. camera, lens, and gimbal). • The sUAS will operate at speeds of no more than 100 knots. • Given the small size ofthe sUAS and the restricted sterile environment within which they will operate, our sUAS operations adhere to the Reform Act's safety requirements. Additionally, the fact that the AEROWAZE pilots will hold, at a minimum, an FAA Private Pilot Certificates demonstrates that they have a high regard to safe operations with an understanding of FARs, pre-flight inspections, maintenance and repair, operations within airspace, as well as being trained to high safety standards. Underthe requested exemption AEROWAZE ensures that all operators have completed a small unmanned aircraft systems (UAS) education and training program including all applicable regulations and guidance documents; including aeronautical background information such as charts, NOT AMS and Aircraft Circulars; Radio Communications Procedures; Human Factors and Crew Resource Management; Basic Small UAS Aerodynamics; Weather Factors; Airmanship and Decision-Making and Safe Operating Procedures. Privacy will be paramount to AEROWAZE, and we will safeguard all data by storing data on hard drives, and not on cloud-based software platforms unless there is a signed agreement in place with all personnel and private property owners in the photos orvideo. We respectfully request exemption under Section 333 to enable AEROWAZE to operate safe, low-risk commercial sUA V operations forthe activities stated. AEROWAZE at all times will respect the space and privacy ofcitizens and property whilst keeping our skies safe. AEROWAZE will be utilizing the same DJI and 3DR Robotics proven technologies the FAA has already scrutinized and approved for other Section 333 exemptions. Furthermore, AEROWAZE would like the FAA to consider that this request is based offof Docket# FAA-2014-0995-0001 and is not precedent setting.

# ;t~ly,**x:#~L-----** William Neuhauser, P.E. Owner AEROWAZE, LLC 21494 Coaley bay Drive Detroit Lakes, MN 56501 218-847-9718

### EXEMPTION REQUESTS AND EQUIVALENT LEVEL OF SAFETY AEROWAZE, LLC requests an exemption from thefollowing regulations as well as any additional regulations that maytechnically applytothe operation ofthe sUAV System: 

### 14 CFR Part 21, Airworthiness Certificates This part establishes the procedures forthe issuance ofan airworthiness certificate. While the FAA continues toworkto develop airworthiness standards for Unmanned Aerial Systems, we request an FAA Modernization and Reform Act, Section 333 Exemption be issued forTarot 680 Pro, Skywalkerx-8 Plane and DJIInspire sUAS underthefollowing provisions: 

### 14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations providethat each aircraft must display "N" and the aircraft's registration number in letters at least 3 inches high. Additionally, the aircraft must displaythe word "EXPERIMENTAL" in letters at least 2 inches high nearthe entrance tothe cabin, cockpit, or pilotstation. The sUAV does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration numberassigned to it by the FAA. We propose to achieve an equivalent level ofsafety by including theword "EXPERIMENTAL" in the placard on thetop ofthe aircraft, as shown above, where the PIC, VO and others in the vicinity ofthe aircraftwhile it is preparing for launch will be able to see the designation. Additionally,we feel thatthe permanent placard discussed in the previous paragraph will provide the aircraft's registration information atthe ground station. Finally, we will display atthe ground station a high contrastflag or bannerthat contains thewords "Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraftwill operate within view ofthe ground station, the banner should be visible to anyonethat observes the aircraft and chooses to investigate its point oforigin. 

### 14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations.The regulation providesthat no person that holds a Private Pilot certificate may act as pilot in Command ofan aircraftfor compensation or hire. Subparagraph (b) allows a private pilotto act as pilot in command ofan aircraft in connection with any business or employment if: (1) The flight is only incidental tothat business or employment; and (2) The aircraft does notcarry passengers or propertyfor compensation or hire. Our proposed operations require thatthe PIC must hold at least a Private Pilot Certificate issued bythe FAA and since the aircraft cannot carry passengers or property,wefeel we meetthe intent of61.113 Subparagraph (b) even though the intentofthis 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 theform contemplated bythe FARs, this Regulation is inapplicable. 

### 14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.
This regulation provides that no person may operate an aircraft unless acurrent, approved flight manual is in the aircraft. We assume thatthe intent ofthis requirement is to ensure that flight manual information is available tothe aircrewwhile operating the aircraft. We request an exemption tothis requirement since the aircraft is notonlytoo small to carry documentation,the documentationwould not be available tothe crew duringflight operations.To obtain an equivalent level ofsafety and meetthe intentof91.9, we propose thata current, approved sUAS Flight Manual must be available tothe crew atthe ground station anytimethe aircraft is in, or preparing for, flight. 

### 14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests. The regulation states that "No person may operate acivil aircraftthat is being used forflight instruction unless that aircraft has fullyfunctioning dual controls." The sUAS System groundbased control station consists ofa small hand-held radio transmitterand while itdoes not offer a second set of "controls", boththe studentand instructor can, and will, operate the single set ofcontrols simultaneously. With both student and instructor having "hands-on" the controls duringflight, we feel thatthistechnique meets the intent 91.109 and provides an equivalent level ofsafety. 

### 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 any person, vessel, vehicle, or structure. Since the typical mission ofthe sUAS would be photography or survey of persons, vessels, vehicles orstructures itwould be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained and careful pre-planned has been performed.The aircraftwill be operated at a lowaltitude allowing, ifa power unitfails, an emergency landingwithoutundue hazard to persons or property on the surface. Therefore we maintain that duetothe small size ofthe UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft,which should be considered in grantingthe 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 ofthe aircraft.The sUAS will always fly below 600 feet AGL and will not need to maintain cruising altitudes in orderto prevent conflictwith other aircraft. An Above Ground Level altimeter measurement above thetakeoff point is transmitted via radio from the sUAS on-board computertothe display screen held bythe 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 aflight in an airplane underday-VFR conditions unless there is enough fuel toflytothefirst point ofintended landing and tofly afterthatfor at least 30 minutes. We feel the intention ofthis paragraph is to provide an energy reserve as a safety bufferfor delays to landing.The sUAS are battery operated and the maximum duration offlightfrom a single battery charge is 12-45 (depending on which sUAS) minuteswith a20% reserve. Since the aircraftwill neverfly more than 1/2 NM from the point ofintended landing, afull battery charge at launch will ensure thatwe meetthe reserve energy requirement ofthis paragraph. We request an exemption totheword "fuel" and ask for an equivalent interpretation with the word "energy". We also request exemptionfromthe 30 min reserve and askthat our reserve will be toflythe mission tothe point ofintended landing and have at least a20% battery reserve afterthat. 

### 14 CFR 91.203(a) 

## & (b) Civil aircraft: Certifications required. The regulation providesthat an airworthiness certificate, withthe registration number assigned tothe aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagraph (b) provides thatthe airworthiness certificate be "displayed atthe cabin or cockpit entrance so that it is legibleto passengers or crew." The sUAS is too small to carry documentation, does not have an entrance, and is notcapable ofcarrying passengers or crew. To obtain an equivalent level ofsafety and meetthe intentof91.203, we propose that documents deemed appropriateforthis aircraft bythe FAA will be collocated with the crew at the ground control station and availablefor inspection upon request. In orderto identifythe aircraft,we propose thatthe informationfound on airworthiness and registration certificatesbe permanently affixed tothe aircraftvia placard containing the following information plus the word "EXPERIMENTAL" to satisfy the requirement of 14CFR 45.23. 

## 14 CFR Subpart E(91.401- 91.417)- Maintenance, Preventive Maintenance, Alterations The regulation providesthatthe operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require thatthe aircraft be "approved for return to service bya person authorized under43.7" after maintenance and inspection. It is our intentionthatthe PIC perform maintenance and inspection ofthe aircraft and "be authorized to approvethe aircraftfor return to service." The PIC will ensure thatthe aircraft is in an airworthy condition priorto everyflight and in addition, conduct detailed inspections after everytwo hours offlight. Maintenance performed bythe PIC is limitedto repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware forthe on-board computer. All other maintenancewill be performed bythe manufacturer ortheir designated repairfacility. The PIC will documentwork performed in accordance with 91.417. We feel that due tothe size, construction, and simplicityoftheaircraft,the PIC can ensure an equivalent level ofsafety.