Unmanned Services

, Inc.

314 S. Main St.

Suite 1
Versailles, KY 40383
Phone: (267) 614

- 1345

August 05 , 2015

U. S. Department of Transportation, Docket Operations
West Building Ground Floor, Room W12

- 140 1200 New Jersey Ave, SE Washington, DC 20590

Re: Amendment to Exemption 12033 issued pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations in Regulatory Docket No. FAA

- 201 5

- 1 3 02

Dear Exemption Manager,

Unmanned Services, Inc. (USI) , is an operator of small Unmanned Aircraft Systems (sUAS) or Unmanned Aircraft (UA). USI is an aviation technology and services company that was issued an Exemption numbered 1 2033 (hereinafter the 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 the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. USI herby requests an amendment to the Exemption to revise conditions 4, 6, 13, 15, and 2 5 of the Conditions and Limitations set forth in Exemption 12033.

Condition 4 states that the UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must b e reported in feet AGL. USI’s request is that exemption be made in that UA altitude reports may also be reported in meters (m) for which 121.92 meters is the equivalent of 400 feet.

Condition 6 states that 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 VLSO requirement as long as the PIC always maintains VLOS capability.

The VO and PIC must be able to communicate verba lly at all times; electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perfo rm the duties required of the VO. USI’s request is that exemption be made in that the PIC may be able to transfer his or her designation during flight operations. The stipulations will be that the transferring PIC will properly log the name of the new PI C and time of transfer, and ensure that the transferee PIC is qualified and current to perform PIC duties before conducting transfer of control.Condition 13 states that a PIC must hold either an airline transport, commercial, private,

recreational, or sp ort 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 Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft which the PIC is rated on his or her pilot certificate. USI has found that most pilots with any one of the above piloting certificates do not usually have the best aptitude for learning to fly complex UA aircraft. This problem is mo st prominent when flying in more manual stick modes of flight that require intensive finite stick

controls or when fast reactions to the aircraft are required since they are not used to flying from the perspective of being on the ground. This problem is m ost pervasive in dealing with emergency situations or a pilot’s inaptitude for troubleshooting aircraft conditions remotely. The training required to get these pilots to our high operating and proficiency standards is time and money intensive, especially when crashes and losses of UAS happen frequently when training these types of pilots. USI’s request is that exemption be made in that the PIC may also be someone who does not hold any of the above piloting certificates as long as the PIC has had prior

mil itary UA S rated piloting experience of at least 1 50 hours and has passed a FAA ground school knowledge test associated with a FAA pilot certificate program within the last 24 months. All military UAS PICs go through aviator tr aining similar to a FAA rated pilot’s training with the exception of flying manned aircraft. They receive similar training in aerodynamics, airspace, airport operations, ATC communications, aviation weather, aeromedicine and crew

- coordination

. Having a PIC fly in this manner increas es safe ty of the operation as the UA will be controlled by a skilled UAS operator instead of a newly trained UA pilot

. USI is willing to provide a standard of tracking and security clearance for its non

- FAA

- certificated UA pilots, such as a TWIC c ard

or m ethod preferred by the Administrator

. T his condition for exemption is only intended to be temporary until the FAA establishes its new system for certificating UA PICs. USI will also follow all future directives from the FAA on moving our PICs to the new UA pilot rating system

once established

.

Condition 15 states that UAS operations may not be conducted during night, as defined in 14

CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. USI’s request is that exemption be made in that UA flights may be conducted during night. Nighttim e flights , whi ch are absolutely necessary for certain uses , are frequently conducted with manned helicopters. Granting this exemption will provide safer operations than using a helicopter. In addition to the PIC and VO, USI will require a second VO for the se operations who will use an assisted

- vision device such as a set of binoculars or a monocle with night vision technology. Additionally, USI

PICs and VOs will familiarize themselves with the intended flight location during daylight hours in a pre flight sc out. The UA will also be well lit with an anti

- collision light system including navigation lights and position strobe lights and never flown over 200 feet AGL in approved COA

locations

Condition 25 states that the UAS may not be ope r ated by the PIC from a ny moving device or

vehicle. USI’s request is that exemption be made in that UA flights may be conducted from moving devices or vehicles. USI has significant experience operating UA Ss from moving platforms such as boats, cars, and golf carts. This is oft en done to help the pilot maintain greater visibility and directionality of the aircraft over long distances. Neither the PIC nor the VO will be tasked with operating the moving platform , will only operate from platforms that provide full unimpeded visibil ity of the sky and will r emain completely focused on the operation of the UAS.If a safety of flight issue occurs, the moving platform will be halted immediately and the PIC

will land the UA in a safe manner and as expeditiously as possible.

USI respectfully submits that good cause exists for not publishing a summary of the petition in the Federal Register because the requested amendment to the Exemption would not set a precedent, and any delay in acting on this petition would be detrimental to th e petitioner.

USI submits that the same conditions and reasons relative to public interest and safety that were the basis for granting the original Exemption still apply. Thusly, a grant of an amendment is in the public interest.

Further, the petitioner agrees to be subject to all conditions and limitations as may be set forth under an approved amendment to Exemption , and u nless otherwise specified in a grant of exemption, the UAS, the UAS PIC, and the UAS operations will comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

The name and address of the petitioner is:

Unmanned Services

, Inc.

Attn: Manfred M. Marotta

314 S. Main St.

Suite 1 Versailles, KY 40383 Phone: (267) 614

- 1345

Email: mmarotta@unmannedser vicesinc.com

Please contact the undersigned should you have any questions concerning this request for an amendment to the Exemption.

Sincerely,

Manfred M. Marotta

CEO , Unmanned Services, Inc.

cc: John S. Duncan

Jake Troutman Margaret Sandkam