3GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Cover Page UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

DOCKET MANAGEMENT SYSTEM 1200 NEW JERSEY AVE., SE

WASHINGTON, DC 20590

R egulatory Docket No.____________

I N THE MATTER OF THE PETITION FOR EXEMPTION OF:



## 3GLP, Inc. dba Precision Flight Devices

F OR AN EXEMPTION SEEKING RELIEF FROM

THE REQUIREMENTS OF THE FAA Reform Act and Part 11 of the Federal Aviation Regulations from

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SEC TIONS C.F.R. §§ 61.113 (a) & (b); 61.133 (a ); 91.9 (b); 91.103; 97.109; 91.7(a); 91.119 (c);

91.121; 91.151(a); 91.203 (a) & (b) ; 91.405 (a); 91.407(a)(1); 91.409 (a) (2); 91.417 (a) & (b).

CO NCERNING COMMERCIAL OPERATION OF UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF THE FAA MODERNIZAT ION AND REFORM ACT OF 2012 (PUBLIC LAW 112

- 95)

January 19, 2015

S tephen Colligan 3GLP, Inc. dba Precision Flight Devices

800 E Dimond Blvd

Suite 3

- 650 Anchorage, AK 99515 (800)756

- 56803GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 1 

## Table of Contents

**GLOSSARY OF ABBREVIATIONS**

**........................................................................................... 2** 

**INTRODUCTION**

**......................................................................................................................... 3** 

**Executive Summary**

**................................................................................................................. 4** 
**Expeditious Summary Grant Approval Request**

**...................................................................... 4**  Description of Type, Make and Models and 333 waiver granted of sUAV/UAS Requested:......................................................................................................................................................... 4 Commercial (Mission, Operation) Purpose:

........................................................................................ 5 Regulations from which the Exemption Relief is requested:

....................................................... 6

**The name and address of the Petitioner:**

**................................................................................... 6** 



### Background

**................................................................................................ ................................**  **. 7**
Expertise & Experience

................................................................................................................................ 7



### The Exemption Request

**......................................................................................................... 9** 
**Operator Requirements**

**................................................................................................................ 10**  **Aircraft and Equivalent Level of Safety**

**.................................................................................... 12**  **Specific Uses and Public Benefits**

**............................................................................................... 16**  **Equivalent Level of Safety**

**............................................................................................................. 17**  14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

...................................... 18 14 C.F.R. § 91.7(a): Civil aircraft airworthiness.

............................................................................. 18

14 C.F.R. § 91.103: Preflight action

...................................................................................................... 18 14 C.F.R. §91.109: Flight instruction:

.................................................................................................. 19
14 C.F.R. §91.119: Minimum safe altitudes

...................................................................................... 19 14 C.F.R. §91.121 Altimeter Settings

................................................................................................... 19 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

.............................. 20 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

..... 20 14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance
Inspections

..................................................................................................................................................... 21



### Federal Register Publication

**............................................................................................. 21** 

**Privacy and National Security**

**........................................................................................... 22** 

**Summary**

**................................................................................................ ...................................**  **22**

**Appendix A –**  **Operations and USER Guides**

**.................................................................. 24** 

**Appendix B -**  **General Safety and Mainten ance Procedures** 

**................................... 25** 
A) Maintenance Schedule

................................................................................................................... 25 B) Record Keeping

................................................................................................................................ . 26

C ) Securing Flight Site

.......................................................................................................................... 26 D) Pre

- Flight Checklist

.......................................................................................................................... 27 E) Mid- Air Safety Protocol

.................................................................................................................. 28 F) Participation by non

- pilot staff

................................................................................................... 283GLP, Inc. dba Precision Flight Devices, 800 E Dimond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 2 

## GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level

AOI Area of Interest

ATC Air Traffic Co ntrol

ATO Air Traffic Organization

AV Aerial Vehicle

CFR Code o f Federal Regulations

COA Certificate o f Authorization

ExtVLOS Extended Visual Line of Sight

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FCC Federal Communication Commission

FPV First Person View

FRMA FAA Modernization and Re form Act of 2012

FSDO Flight Standards District Office

GCS Ground Control Station

GPS Global Positioning System

LOL Loss of Link

NAS National Airspace System

NOTAM Notice To Airman

PIC Pilot In Command

Section 333 FAA Modernization and Reform Act o f 2012 (FMRA) Section

333

SO Safety Observer

SOP Standard Operating Procedures

STEM Science Technology Engineering and Mathematics

sUAS Small Unmanned Aircraft System

sUAV Small Unmanned Aircraft Vehicle

UA Unmanned Aircraft

UAS Unmanned Aircraft System

UAV Unmanned Aircraft Vehicle

VFR Visual Flight Rules

VLOS Visual Line o f Sight

VMC Visual Meteorological Conditions

VTOL Vertical Take

- Off and Landing3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 3 

## INTRODUCTION

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Mo dernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, 3GLP, Inc dba

. Precision Flight Devices , (“ PRECISION FLIGHT DEVICES ”) Operator of Small Unmanned Airc raft Systems (“sUASs”) equipped to offer on

- demand commercial UAS operations f or a host of industries and applications and to perform the purposes

listed below

, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUAV’ s /UAS , so long as such operations are

conduct ed within and under the conditions outlined herein or as may be established by the FAA in an exemption granted under either Section 333 or Section 49 U.S.C. §44701(f)

As described more fully below, the requested exemption would permit the operation of a UAS under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide safety enhancements in the fields in which it will operate, which now depend upon conventional aircraft or humans climbin g high on da ngerous structures, walking in wetlands , and working on or observation of steep terrain or infrastructure. To

the extent necessary to allow PRECISION FLIGHT DEVICES to commercially operate a

UAS to perform aerial data collection to include any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared/thermal, etc.), electronic measurement (precision surveying, RF analysis, 3D mapping, multispectral imagery, LIDAR, etc.), chemical measurement (particulate

measurement, etc.), or any other gathering of data by instruments aboard the UAS. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities to “... establish requirements for

the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act. 1

1 Precision Flight Devices relies upon the following exemptions where specific reference to an exemption is not provided: Exemptions 11062, 11063, 11064, 11065, 11066, 11067,
11080, 11109, 11110, 11111, 11112, 11114, 11213, 11062, 11857, 11398, 11277, 12515, 12496, 11277, 11356, 11206, 11281, 12516, 12580, 11373A, 11238A, 11239, 11239A, 12505,
12103, 12068, 12208, and 11675.



### .3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 4 

## Executive Summary

**Expeditious Summary Grant Approval Request**

The PRECION FLIGHT DEVICES requests the agency issue a summary grant process for this application. PRECION FLIGHT DEVICES has provided in a confidential document attachment

labeled as PRECION FLIGHT DEVICES proprietary information, specific exemption numbers whereby the FAA has already granted a previous exemption similar or identical to ea ch and every request, herein.

PRECION FLIGHT DEVICES has identified previous approved exemptions for each of the

PRECION FLIGHT DEVICES FAA submission requests:

• Commercial (mission/operation) purposes;

• Type of sUAV’s (UAS);

• Title 14 Exemptions applica ble to each aircraft



### Description of Type, Make and Models and 333 waiver granted of sUAV/UAS Requested:

The PREC IS ION FLIGHT DEVICES is seeking an exempt ion to commercially operate sUAV’s

makes and mode l s as follows:



### Aircraft **Flight Controller Configurat**  **ion FAA 333 #** 

DJI

- Phantom 2 DJI X Config Multi Rotor 11784. 11795, 11785,

11767 DJI

- Phantom 3 DJI X Config Multi Rotor 11783, 11788, 11711,

11696 DJI

- Inspire 1 DJI X Config Multi Rotor 11710, 11711, 11712,

11714 DJI

– Spreading Wings S800 DJI / 3DR Pixhawk, APM Hex Config Multi Rotor

.8M 11788, 11756, 11401,

11252

DJI

– Spreading Wings S900 DJI Octo Config Multi Rotor

.9M 11794, 11779, 11714,

11697

DJI

– Spreading Wings S1000 DJI Octo Config Multi Rotor

1M 11671, 11672, 11677,

11638

DJI

– Matr ic e 100 DJI X Config Multi Rotor,

.65M 11814

3DRobotics X8 3DR Pixhawk Coaxial X Multi Rotor 11379

3DRobotics Iris 3DR Pixhawk X Configuration Multi

Rotor 11778, 11533, 11496,

11673

3DRobotics Solo 3DR Pixhawk X Configuration Multi

Rotor 11832

3D Robotics AeroM 3DR Pixhawk Fixed Wing, 1.88M 113793GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 5 *1 CumulUS ma terial equivalent to 3DRobotics AeroM *2 Material equivalent to DJI Phantom 2 and 3DR IRIS *3 Material equivalent to DJI 550 333# 11397 and 3DR Solo *4 Material equivalent to 3DR X8 multi rotor *5 Material equivalent 3DR Solo

E ach separately weighs 55 lbs . or less, with imaging payload and applicable equipment.

Equipment operation manuals for each sUAV are included for your reference and are

considered confidential information for each respective company’s UAS and are affixed separately in these documents labeled Appendix

.



### Commercial (Mission, Operation) Purpose:

This exemption request

, once granted would allow the PRECION FLIGHT DEVICES to operate a small unmanned aerial vehicle (sUAV), (55lb s or less) f or geospatial survey ing

, measurement and inspections, c ollection of p hotographs and video and b roadcast of video and telemetry data

. f or the following purposes: Geographic mapping, delineation, measuring and 3D modelling of terrain , infrastructure or manmade improvements, Use of sensors on UA for vegetation mapping environmental monitoring, quantification and calculation of area and health of materials, plumes, natural and mineral resources. Video capture for commercial collection and observation to be used in commercials, training videos, doc umentation, recoding of events, environmental observation, counting and classification of physical, natural or mineral resource activity or development. Training to persons individually or belonging to private or public organizations to increase awareness and improve safety for current and futur e UAS operations

within the NAS.

PFD CumulUS 3DR Pixhawk Fixed Wing, Tracktor, 1.7M Span 11379* 1

PFD X

- 450 3DR Pixhawk/DJI NAZA X config Multi Rotor .45M 11784. 11795, 11785,

11767 *2 PFD

- 550 3DR Pixhawk/DJI NAZA Octo Multi Rotor .5M 11379* 3

PFD CX

- 850M 3DR Pixhawk CoAxial X Config .85M 11379* 4 AscentAeroSystems Sprite

, 3DR PixHawk/APM Single Coaxial Blades 11778, 11533, 11496,

11673 *5

Altavian Nova F6500 Altavian Nova Fixed Wing Tracktor 11456, 11472, 11605,

11552 Sense Fly eBee Sense Fly, eMotion Fixed Wing Delta, .96M 11745, 11754, 11764,

11673 Topcon Sirus MAVinci Fixed Wing Tracktor,

1.63M 11368

Topcon Falcon 8 AscTec Multi Rotor 8

Trimble UX5 Trimble Fixed Wing Delta, 1M 11806, 11666, 11432,

113293GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 6 

### Regulations from which the E xemption Relief is requested :

14 C.F.R. § 61.113 (a) & (b) 14 C.F.R. § 61.133(a) 14 C.F.R. § 91.7(a)

14C.F.R. § 91.9 (b) 14 C.F. R.§ 91.1 03

14 C.F. R. § 91.1 0 9 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) 14 C.F.R. § 91.405 (a) 14 C.F.R. § 407 (a) (1) 14 C.F.R. § 409 (a) (2) 14 C.F.R. § 417 (a) & (b )



## The name and address of the **Petitioner :** 

3GLP, Inc dba Prec ision Flight Devices

Attn: Stephen M Colligan Mailing : PO Box 874294

, Wasilla, AK 99687 Physical: 800 E Dimond Blvd, Suite 3

- 650, Anchorage, AK 99515 Phone: (800)756

- 5680 SColligan@PrecisionFlightDevices.com3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 7 

## Background

3Glp, Inc was established in 1994 as a Alaska holding and investment c orporation to several emerging technology and geospatial companies. With industry leading skills in geomatics, internet and cloud computing, aerial and satellite image processing, aviation safety and flight simulation, 3Glp formed a Unmanned Systems company to focus on the design, integration, application and t raining needs of the emerging sUAS market. 3Glp, Inc and its subsidiaries have mapped millions of kilometers of the earth’s surface using a variety of technologies and

sensors to create the best geospatial data available. Most of the geographic focus has bee n in the northern and arctic regions

, but also has significant experience in the continental US and

Canada.

3GLP, Inc, Precision Flight Devices and its sister companies are made up of leaders in their field

of Engineer ing , Geo spatial Scien ce , Manned Aircr aft Pilots, Air Traffic Control professionals, Military UAS operators, Aviation Safety Management, Remote Control aircraft pilots and Electronics and communications equipment. 3GLP, Inc has assembled an advisory board for Precision Flight Devices of leade rs and advisors in each area of anticipated operation al areas of UAS to ensure that it meets or exceeds Federal Regulations and set an example for others in the community.

3Glp,Inc, Precision Flight Devices, founder, Steve Colligan has over 25 years’ experience i n Geographic Information Systems, Computer Aided Design and 35 years of Remote control aviation building and flying experience. As a lifelong Alaskan resident he has been involved in the aviation industry and aviation safety, directing mapping operations and developing aviation safety simulation and training tools addressing and improving Alaska’s unique challenges.

Mr. Colligan has been a member of the Academy of Model Aeronautics (AMA) , UAS advisory board working to establish best practices and training for A MA members. Mr Colligan is also one of the initial members on the State of Alaska’s UAS legislative task force working to protect public privacy and safety, while also creating opportunity for the safe and meaningful operation on Unmanned Aircraft Systems . Mr. Colligan is also a county level elected official, where he a great amount of experience in the development of municipal and state government code and public policy.



### Expertise & Experience

Steve Colligan formed Prec i sion Flight Devices over the pa st three years by developing flight systems, sensors, software and workflows to produce accurate geospatial data using sUAS platforms that extend or enhance existing geospatial business lines . M r C o lligan has built relationships and vendor contracts to de liver market acceptable data efficiently and safely, and participate in Research and Development projects to evolve the sUAS technology into the future.

Steve Colligan due to his professional industry experience in engineering, geomatics and as a

trusted sUAV pilot i s extremely qualified and is subject mat t er expert in Alaska and the US for

s UA S of all types

.3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 8 3GLP, Inc Precision Flight Devices has been working with NASA AMES through i t s relationship with Northern Regions Research and Development Institut e (NRRDI.org pronounced “NERDY”),

its sister company E

- Terra and environmental services company Fairweather Sciences on the Unmanned Traffic Management System (UTM) in the Arctic. Precision Flight Devices has been building and integrating communications e quipment and telemetry sensors to broadcast to the UTM cloud based reporting system.

Precision Flight Devices , has developed its own training, operations and maintenance program and safety management system to respond to market needs based on a solid cult ure of safety. Precision Flight Devices, employees, contractors and board members have many years of experience in commercial aviation, air traffic control, safety management and training. Precision Flight Devices will meet or exceed Federal regulatory r equirement of the sUAS industry.

Precision Flight Devices, has a lease agreement for a large area of land well suited for sUAS training which will be of great benefit to the public as a safe place to train and operate future operators creating economic be nefit to the community and public at large . Precision Flight Devices intends to work with federal regulatory agencies and industry to provide market driven training courses that are affordable and meaningful.

Furthermore, Precision Flight Devices being a n Alaskan company has been working closely with it Alaska Native Corporation clients to provide STEM education opportunities using sUAS. Precision Flight Devices, is leveraging its relationship with NASA AMES and the UTM system to integrate into mapping, vegetation analysis and geographic media collection curriculum and projects.

During the summer of 2015, Precision Flight Devices developed a project with high school interns to research and develop the use of haptic and audio feedback with RC transmitters for sUAS use. The end result was a complete library of audio messages and a framework of alarms and feedback to keep the sUAS pilot focused on the flying aircraft. The telemetry system is now used in all Precision Flight Devices custom sUAS and part of our operations and procedures

manual.3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 9 

## The Exemption Request

3Glp, Inc Precision Flight Devices proposes the use of the sUAV’s will be for capture of high resolution imagery and video of earth and developed infrastructure to a level of quality that

allow s the PRECION FLIGHT DEVICES to use the data to produce mapping, video and three

dimensional models for commercial use.

The imagery and video will be used to identify the condition of the earth surface and developed

infrastructure. Uses of the data will be used by a wide variety of clients from environmental monitoring and wetlands delineation to electrical and communications towers.

The UAS will be operated by a Precision Flight Devices and or contracting operators on
occasion to capture high

- resoluti on imagery/video of terrain and infrastructure. Given the small

size of the sUAV’s involved, no more than 5 5 lbs., majority of the speed of operation be

between 5

- 25 mph and the restricted environment within which they will operate, the PRECION

FLIGHT DEVI CES falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of

UASs to commence i mmediately.

This exemption application is submitted to fulfill Con gress’ express goal in passing Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

• The UA S’ size, weight, speed, and operational capability;

• Operation of the UAS in close proximity to airports and populated areas; and

• Operation of the UAS within visual line of sight of the Operator.

Reform Act § 333 (a). Lastly, if t he Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system. ” Id. §333(c) (emphasis added).

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act: The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702

- 44716 of this title if the Administrator finds the exemption is in the public interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §9 1.203(a)(1) This authority to grant exemptions reaches such issues as authorization of commercial operation of aircraft without an FAA issued pilot’s license.

PRECISION FLIGHT DEVICES in filing this application is requesting that the FAA combine the
grant of the Section 333 exemption with a standard Certificate of Operation (COA) that will allow commercial operations of its PRECISION FLIGHT DEVICES ’ sUAV without the necessity of filing for a COA for each flight, unless such flight is to be conducted in an area not approved in the exemption. Compliance with the conditions agreed to herein and that may be imposed by3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 10 the FAA, as set forth in prior Section 333 exemptions, provide the separation needed from other

aircraft.

In addition, given that all operations will be conducted below 400 AGL feet and no closer than 5 nautical miles of the geographic center of an airport as denoted on a current FAA published aeronautical chart, unless a letter of agreement with that airport’s management is obtained,

PRECISION FL IGHT DEVICES requests that operations over congested or densely populated

areas be allowed. The new sUAV’s do have GPS geo

- fencing, it will operate at a very low
altitude, within confined areas, at low speed and weighs no more than 55 lbs.. Such operations will only be under

- taken with the approval of the land or home owner , as set forth herein, and

will comply with the requirements that operations be no closer than 500 feet to the adjacent building unless the land owner has provided permission, and the Ope rator has made a safety

assessment of the risk from such operations.



## Operator Requirements

Given the sUAV proposed by PRECISION FLIGHT DEVICES , Operators should not be required

to hold a private pilot license. PRECISION FLIGHT DEVICES believes t hat 1) t he operator,

instead of understanding how to operate a passenger carrying aircraft, should have knowledge and experience that enables the safe operati on of a small, remotely piloted sUAV should understand airspace restrictions and know how to ensure separa tion from other aircraft as well

as non

- participants and property; 2) the sUAV has built

- in technical capabilities that limit the potential for unsafe operation and 3) there are other security screening mechanisms already in

existence that PRECISION FLIGHT DEVICES will utilize to ensure the operators are acting

cons istently with national security interests.

Given the sUAV safety features outlined below, PRECISION FLIGHT DEVICES proposes that

its operations under this Exemption request should not be requir ed to hold a commercial or private pilot certification. Instead, Operators should be required to: have successfully completed, at a minimum, FAA p rivate pilot ground instruction and passed the FAA Private Pilot written

examination or FAA

- recognized equival ents; have completed PRECISION FLIGHT DEVICES ’ training program for operation of the UAS.

PRECISION FLIGHT DEVICES notes that 1) the FAA has found that safety factors permitted operation of sUAV’ s by Operators with these qualifications in the case of oper ations pursuant to public COAs when the mandatory operating conditions specified above were present; and 2)

that the Notice of Proposed Rulemaking entitled Operation and Certification of Small Unmanned

Aircraft Systems, 80 F.R. 9544 (February 23, 2015) (“N PRM”), does not require the operator to

hold a private pilot license or a third class medical.

Advanced sUAV’s has a navigation and control system and auto

- pilot that allow s it to execute very accurate pre

- programed flights. Flights are p re

- programmed wi th GPS waypoint to establish perimeters beyond which the aircraft will not operate. Flights under auto

- pilot are not directed by positive manual input, but through pre

- programmed flight parameters that are executed by the auto

- pilot. In the case of unplann ed events, the Operator inputs preprogrammed evasive maneuvers from the control unit, and the autopilot executes those

maneuvers. Pre

- programmed Operator interventions include : initiation of holding at present position; suspension of mission; fly back to l aunch point; abort mission and land immediately;3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 11 and emergency power cut off and land (flight termination system). Additional automated safety functions and safety enh ancing features of the advanced sUAV’s may include the following:

1) Auto

- pilot detectio n of lost GPS or of insufficient satellites initiates an immediate landing, 2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. Low power be low 10 % triggers an immediate landing, 3) If the auto

- pilot detects a lost

- lin k to the ground controller, the UAS will hold position at its current location for 5 seconds and if the signal is not restored, execute a return to home and land, 4) Redundant “kill switches” that enable completely shutting the aircraft down in flight in the

event of a loss of control or un

- commanded devi ation from the flight path, 5) The aircraft, weighs less than 55 lbs., fully loaded, 6) The motors are driven by pulse width modula ted signals, not analog signals, 7) The aircraft will operate for th e Purposes at no more than 30 mph (while imaging) nor above 200 feet above the structure (imaging a ltitude) or a maximum of 400 fe et AGL.

See Federal Aviation Administration, Notice N

- 8900.227, Unmanned Aircraft Systems (UAS) Operational Appr oval, at 20

- 21 (July 30, 2013); As the FAA has determined in Exemptions 11062 thru 11067,11080 and 11110 (the “Exemptions”), in comparing the requirements for private pi lot knowledge and the knowledge required for a commercial pilot, that knowledge associated with a p rivate pilot license, and therefore private pilot ground school, was sufficient

to allo w private pilots to operate sUAV’ s under those exemptions.

Based upon that analysis, PRECISION FLIGHT DEVICES believes successful completion of FAA private pilot groun d school is a suitable predicate to operating the sUAV under this exemption. PRECISION FLIGHT DEVICES proposes that the O perator accumulate required

sUAV flight training hou rs through the operation of sUAV’ s rather than flight hours in

conventional aircraf t. Those hours are more relevant to the operations proposed herein than hours gained in obtaining a private pilot’s certificate in conventional or rotor aircraft. Those aircraft are orders of magnitude heavier than the sUAS and carry not only the pilot him self, but also passengers and fuel, none of which is carried in the sUAS. These conventional aircraft fly over all sorts of airspace without the permission or knowl edge of the landowner

.

A handheld radio controller controls the sUAV and the vehicle is op erated within the line of sight. The requirements of Part 61.127 (commercial flight proficiency) and §61.107 (private flight proficiency), to the extent they are relevant to UAS operations, can be taught in the training

pro posed herein. As a review of the requirements of part 61.127 and 107 demonstrate, the issues presented as they relate to a 55 pound aircraft, operating at less than 30 mph during filming operations are those taught in ground school and in flight training with the par ticular UAS and not ga ined from accumulating flight hours in a fixed wing or rotorcraft gas or jet A powered aircraft completing cross country flights and take offs and landings at controlled and uncontrolled airports.

As to national security review of pilots, each of PRECISI ON FLIGHT DEVICES ’ s pilots/operators will obtain internally provided certified training ( Ground and Practical) from

PRECISION FLIGHT DEVICES t o o perate the sUAV . This review and certification could reasonably vet the Operators against any known terrorist o r no fly listings that are relevant and publically available.

PRECISION FLIGHT DEVICES additionally asks that the exemption be iss ued without the requirement for a visual observer. As set forth herein, an equivalent level of safety is provided3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 12 by the size

, speed and control capabilities of the aircraft, as well as the operational procedures

that will be applicable to all flight hereunder. These obviate the need for the visual observer.

The Operator will be operating the aircraft, always within line of si ght. He or she will walk and

follow the aircraft around the inspection area so that while it is flying it’s pre

- programed and at times, manual flight path, the UAS will always be directly in his or her line of sight. The Operator will not be distracted by viewing the pictures taken during t he flight. Rather, once the sUAV is launched, the Operator’s only duty will be to watch the flight of the UAS over the structure and intervene to address flight path deviations or other issues that arise during the flight . The functions that an observer performs where the aircraft is flown at long distances from the launch area will not be necessary as the Operator will always have the aircraft in his or her direct sight.

The observer also will not be necessary because the Operator will conduct a pre

- flight inspection of the area, will and if needed, cordon off the area and will perform frequent visual scans of the area while the vehicle is operating.

PRECISION FLIGHT DEVICES again notes that the NPRM does not require the use of a visual observer. Given the clear direction in Section 333 of the Reform Act; the authority contained in

the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public ben efit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing battery powered

sUAV’ s for these functions instead of turbine or gas power aircraft/rotorcraft and operations with pilots having at le ast a private pilot license, the grant of the requested exemptions is in the public interest. 2



## Aircraft and Equivalent Level of Safety

The PRECION FLIGHT DEVICES proposes that the exemption requested here in apply to civil

aircraft that have the charac teristics and that operate with the limitations listed herein. These

limitations provide for at least an equivalent or even higher level of safety to operations under

the current regulatory structure because the proposed operations represent a safety

enhan cement to the operations conducted with conventional aircraft or with humans climbing up

and around structures. These conditions are drawn from Exemptions 11136, 11138, 11172,

11174 and 11177, 11062, 11109, 11112, and 11213 and as recent as 11857.

These l imitations and conditions to which PRECISION FLIGHT DEVICES (referred to as “Operator”) agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1) Operations authorized by this grant of exempt ion are limited to the ai rcraft described in the Operator’s manual, which is a aircraft weighing up to 5 5 pounds: Proposed

2 Should the FAA determine that it cannot grant such an exemption for operatio ns without a FAA licensed private pilot, despite the showing made herein, under the statutory authority the FAA already has, Precision Flight Devices will operate its aircraft with pilots holding at least a private pilot certificate issued by the FAA. In t hat event, Precision Flight Devices requests that the exemption be granted with conditions similar to those contained in numbered paragraphs 14

- 15 in Exemption 111363GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 13 operations of any other aircraft will require a new petition or a petition to amend this
grant.

2) The s UA S may not be flown at an indicated airspeed exceeding 30 mph ( 10 mph during inspections).

3) The s UA S must be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the Operator’s manual. All altitudes reported to ATC must be in feet AGL.

4) The s UA S must be operated within visual line of sight (VLOS) of the Aircraft Operator

at all ti mes. This requires the Aircraft Operator to be able to use human vision unaided by any device other than corrective lenses

. .

5) The Exemption Holder’s Manuals must be amen ded to include all conditions and limitations required by the FAA. The Manuals must be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in the exemption and the procedures outli ned in the Exemption Holder’s Operator’s manual, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, the Aircraft Operator must follow the procedures as

outlined in its Aircraft’s manual. The Exemption Holder ma y update or revise its Manuals. It is the Exemption Holder’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The Exemption Holder must also present updated and revised documents if it peti tions for

an extension or amendment of this exemption. If the Exemption Holder determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the Exemption Holder must petition for amendment to its exemption.

6) Prior to each flight, the Aircraft Operator must inspect the UAS to ensure it is in a condition for safe flight. 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. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.

7) Any UA S 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 Exemption holder’s

Manuals. The Aircraft Operator 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 Exemption Holder’s Operator’s manual

.

8) The Exemption Holder must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention to flight critical components that may not be addressed in the

manufacturer ’s manuals.

9) The Exemption Holder must carry out its maintenance, inspections, and record keeping requirements in accordance with the Operator’s Manuals. Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 14 hours, description of work accomplished, and the signature of the authorized technician returning the UAS to service.

10) The authorized technicians must receive and document training referenced in the Exemption Holder’s Manuals.

11) Each UAS operated under this e xemption must comply with all manufacturer System and Safety Bulletins.

12) The Exemption Holder’s maintenance personnel must make a record entry in the UAS logbook or equivalent document of the corrective action taken against discrepancies

discovered between inspections.

13) Prior to commencing operations, the Aircraft Operator shall have logged at least 25 hours of total time as a UA rotorcraft pilot and at least ten hours logged as a UA pilot with a similar UA type and 5 hours in the make and model.

14) If the UAS l oses communications or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property and land or be recovered in accordance with the Exemption Holder’s Manuals.

15) The Aircraft Operator must abort the f light in the event of unpredicted obstacles or emergencies, including unauthorized people entering the flight area, in accordance with the Exemption Holder’s Manuals.

16) The Aircraft Operator is prohibited from beginning a UAS flight unless (considering

wind and forecast weather conditions) there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 10

minutes.

17) All aircraft operated in accordance with the exemption must be identified b y 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.

18) Before conducting operations, the radio frequency spectrum u sed for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

19) The documents required under 14 CFR 91.9 and 91.203 must be available to the Operator 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.

20) The UA must remain clear and yield the right of way to all other manned operat ions and activities at all times (including, but not limited to, ultra

- light vehicles, parachute activities, parasailing activities, hang gliders, etc.).

21) The UA may not be operated by the Aircraft Operator from any moving device or

vehicle.3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 15 22) UAS operations may not be conducted during night, as defined in 14 CFR 1.1.

23) All operations must be conducted under visual meteorological conditions (VMC). The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally

from a cloud or when visibi lity is less than 3 statute miles from the Operator.

24) During operations the UA may not operate within 5 nautical miles of the geographic center of an airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that air port’s management is obtained, and the operation is conducted in accordance with a NOTAM, if as required by the Operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.

25) The UA may not be operated over congested or densely populated areas unless the conditions set for in #26 are satisfied. These populated areas include but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Section als), or Terminal Area Charts (TAC). However, aeronautical charts may not reflect pertinent local information. Ultimately, it is the Operator’s responsibility to maintain the minimum safe altitudes required by § 91.119 (d) (1).

26) Flight operations must be c onducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

27) Barriers or structures are present that sufficiently protect nonparticipating persons

from debris in the event of an accident. The Aircraft Operator mu st ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 30 feet of the UA, flight operations must cease immediately and/or;

28) The aircraft is operated nea r vessels, vehicles or structures where the land owner/controller has granted permission and/or the Aircraft Operator has made a safety assessment of the risk of operating closer to those objects and;

29) Operations near the Aircraft Operator do not present an undue hazard to the Operator per § 91.119(a).

30) All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized rep resentative will be obtained for each flight

to be conducted.



### 31) 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 Integr ation Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions

contained on the NTSB Website: www.ntsb.gov



### .3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 16 

## Specific Uses **and Public Benefits** 

PRE CISION FLIGHT DEVICES proposes use of its sUAV provided equivalent or augmented

levels of safety for each of the uses proposed herein:

To commercially operate a UAS to perform aerial data collection

, to include any remote sensing and measuring by an inst rument(s) aboard a UA. Examples include imagery (photography, video, infrared/thermal, etc.), electronic measurement (precision surveying, RF analysis, 3D mapping, multispectral imagery, LIDAR, etc.), chemical measurement (particulate measurement, etc.), o r any other gathering of data by instruments aboard the

UAS.

To perform training and certification of other commercial UAS operators, state local and federal agencies on the safe operations of UAS for geospatial data collection, surveying

and other uses t hat benefit the public. To educate the public about the process of collecting data in a safe manner and the processing of collected data and workflows that produce data products that are consistent with industry standards and accuracies.

To advance STEM education opportunities especially to Alaska Native and rural

communi ties through the operations of s UAS contributing to multi

- media communications, mapping and robotics curriculum’s

.

To further work with NASA AMES in participation in the Unmanned Traffic Management System development and use cases particular to the Arctic and Northern Regions.

The present systems of photography and videography and mapping of in specting the roofs, agriculture land, buildings and large structures site surveys, wild life mo nitoring, mosquito and

insect control are now conducted by either humans wading through swamps, climbing on the

roofs and structures that are steep, tall, slippery, weakened or otherwise hazardous or by the

use of conventional aircraft.

The current proc edures can result in significant injuries to the people who must climb on the roofs or require the use of aircraft that are orders of magnitude greater in size than the sUAV

. Either method, manual inspection or large conventional aircraft, results in incre ased risk of injury due to personnel falling off roofs or ladders, carrying heavy ladders and dealing with confined and dangerous spaces, or i ncreased risk from low altitude flyovers with helicopters or fixed wing aircraft inspecting buildings after damage from storms or other disasters, such as earthquakes or fires. Such flights are, of course, significantly more expensive t han those undertaken with a

sUAV

. All of these activities directly correlated to Workers Comp rates which will be where

sUAS technolo gy will gravitate to as a solution for safer operations.

The present system exposes those not only in the immediate area of inspection, but those who are along the path of flight associated with the arrival and departure of the conventional aircraft

at th e inspection site because the aircraft must be flown to and from the site. By contrast, the

sUAV is carried to the site and transits no other property. Conventional aircraft carry flammable fuels that are not carried by the UAS and emit pollutants associat ed with inter nal combustion engines. The sUAV’ s proposed herein are battery powered and have no emissions.3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 17 

## Equivalent Level of Safety

14 C.F.R. § 61.113(a) & (b);: Private Pilot Privileges and Limitations; Pilot in Command;

Section 61.113(a) & (b) limi t private pilots to non

- commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the PRECISION FLIGHT DEVICES ’ sUAV is remotely controlled with no passengers or property of others on board. Section 61.133(a) requir es an individual with a commercial pilot’s license to be pilot in command of an aircraft for compensation or hire.

PRECISION FLIGHT DEVICES respectfully proposes that Operator requirements should take

into account the characteristics of the particular UA S. PRECISION FLIGHT DEVICES ’ sUAV has a high degree of pre

- programmed control and various built

- in technical capabilities that strictly limit the potential for operation outside of the operating conditions set forth in the exemption application. The PRECIS ION FLIGHT DEVICES ’ sUAV has navigation and control system comprised of a Ground Control Station (GCS) and auto

- pilot system that can be pre

programme d to set operational boundaries . All flights are pre

- programmed with precision GPS guidance.. In the case of unplanned events, the Operator may input pre

- programmed evasive maneuvers from the control unit, and the onboard autopilot executes those maneuvers. Pre

programmed Operator interventions include initiation of holding at present position; suspension

of m ission; fly back to launch point; abort mission and land immediately; and emergency power cut off and land (Flight Termination System).

Additional automated safety functions and safety enhancing features of the PRECISION

FLIGHT DEVICES ’ sUAV’s may includ e the following:

• Auto

- pilot detection of lost GPS or of insuf ficient satellites initiates an immediate landing.

• Low power on the aircraft triggers escalati ng alarms at GCS at 35% and 10% levels. Low power below 10% triggers an immediate landing.

• If the aut o

- pilot detects a lost

- link to the groun d controller, the UAS will hold position at its current location for 5 seconds and if the signal is not restored,

execute a return to home and land.

• Redundant “kill switches” that enable completely shutt ing the aircr aft down in flight in the event of a loss of control or un

- commanded deviation from the flight path.

• T he aircraft, weighs less than 5 5 lbs., fully loaded.

• The motors are driven by pulse width modulated signals, not analog signals.

• The aircraft will operat e for the Purposes at no more than 30 mph (while imaging) nor above 200 feet above the structure (imaging altitude) or a maximum of 400

AGL.

Given these safety features, PRECISION FLIGHT DEVICES proposes that Operators of the

PRECISION FLIGHT DEVICES ’ sU A S should not be required to hold a commercial or private pilot certification.

Instead, Operators should be required to: have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA

recognized equivalents; have completed the manufacturer’s or Precision Flight Devices ’ training program for operation of the UAS.3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 18 Precision Flight Devices notes that the FAA has found that safety factors permitted operation of UASs by Operators wit h these qualifications in the case of operations pursuant to public COAs

where the mandatory operating conditions specified above were present. See, Federal Aviation
Administration, Notice N

- 8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, a t

20

- 21 (July 30, 2013). Likewise, Precision Flight Devices notes that the NPRM does not require

that the Operator hold a private pilot license issued by the FAA.

Given these conditions and restrictions, an equ ivalent level of safety will be provided by a llowing operation of the Precision Flight Devices ’ sUAV without a private pilot’s certificate or a commercial pilot’s certificate, under the conditions set forth herein.

The risks associated with the operation of the Precision Flight Devices ’ sUAV (giv en its size, speed, operational capabilities, and lack of combustible fuel) are so diminished from the level of

risk associated with private pilot operations or commercial operations contemplated by Part 61

with conventional aircraft (fixed wing or rotorcraft ), that allowing operations of the UAS as set

forth above meets or exceeds the present level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring a commercial pilot to operate the aircraft under § 61.133(a).



### 14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may operate a U.S.

- registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, un less there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any

combination thereof.

The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no room or capacity to carry such an item on the aircraft. The equivalent level of safety will be maintained by keeping the flight manual at the ground con trol point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 32827, and 10700.



### 14 C.F.R. § 91.7 (a): Civil aircraft airworthiness.

This regulation requires that no person may operate a civil air craft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the UAS without an airworthiness certificate, no standard will exist for airworthiness of the UA. Given the size of the aircraft and the requirements that the Operator has agreed to as it relates to airworthiness, as contained in the manual, an equivalent level of safety will be achieved by insuring

comp liance with the manuals prior to each flight. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and 11110.



### 14 C.F.R. § 91.103: Preflight action

This regulation requires each pilot in command to take cert ain actions before flight to ensure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 19 exemption will be needed. An equivalent level of safety will be provided as set forth in the

Manual. The PIC will t ake all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight.



### 14 C.F.R. §91.109: Flight instruction:

Section 91.103 provides that no person may operate a c ivil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls.

sUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight contro l is accomplished through the use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a number of aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K & 9862A. The equivalent level of safety provided by the fact that neither a pilot nor passengers will be carried in the aircraft and by the size and speed of the

aircraft.

Safe simulation and practice fli ght will be carried out in controlled environments. All simulations will be carried out on a computer using the drone controls. Any practice flying will take place in a safe environment, with no risk to human life below.



### 14 C.F.R. §91.119: Minimum safe al titudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 4 00 AGL, an exemption may be needed to allow such operations.

The equivalent level of safety w ill be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner, facility owner, and/or local officials. Because of the advance notice to the

pr operty owner and participants, all affected individuals will be aware of the planned flight operations as set forth in the Manuals. Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. and the lack of flammab le fuel, any risk associated with these operations is far less than those presently presented by conventional aircraft operating at or below 500 AGL in the aerial photography industry. In addition, the low

- altitude operations of the sUAS will ensure separa tion between these small

- UAS operations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and

11110.



### 14 C.F.R. §91.121 Al timeter Settings

This regulation requires each person operating an aircraft t o maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the Precision Flight Devices ’ sUAV , in manual3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 20 or emergency mode, will not have a barometric altimeter display, but instead a GPS altitude display, an exemption will be needed. The Operator, pursuant to the procedures set forth in the

Manuals as indicat ed before flight, will achieve an equivalent level of safety . The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080

and 11110.



### 14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 9 1.151(a) prohibits an individual from beginning “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.”

The battery powering the sUAS provides appr oximately 40 minutes of powered flight. To meet

the 30

- minute reserve requirement in 14 CFR §91.151, sUAS flights would be limited to approximately 10 minutes in length. Given the limitations on the UA S’ proposed flight area and the location of its proposed operations within a predetermined area, a longer time frame for flight is reasonabl e.

PRECION FLIGHT DEVICES believes that an exemption from 14 CFR §91.151(a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to
operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly

controlled area where only people and property owners or official representatives who have signed waivers will be allowed, with less than 30 minutes of reserve fuel, does not engender the type of risks that Section 91.151(a) was intended to a lleviate given the size and speed of the

small UAS.

PRECION FLIGHT DEVICES believes that an equivalent level of saf ety can be achieved by limiting flights to 30 minutes or 25% of remaining battery power whichever happens first. This

restriction would be m ore than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, 10808 and Exemptions 11062, through11067, 11080 and 11110.



### 14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent part: (a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following: (1) An a ppropriate and current airworthiness certificate. . . . (b) No person may operate a civil aircraft unless the airworthiness certificate (1) required by paragraph (a) of this section or a special flight authorization

issued under §91.715 is displayed at the cabin o r cockpit entrance so that it is legible to passengers or crew.

The sUAS fully loaded weighs no more than 55 lbs and is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration documents or to displa y them on the sUAS.3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 21 An equivalent level of safety will be achieved by keeping these documents at the ground control point where the pilot flying the sUAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.



### 14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b):

Maintenance Inspecti ons

These regulations require that an aircraft Operator or owner “shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies re paired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain the aircraft in compliance with Part 43.

Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not app ly to the PRECION FLIGHT DEVICES . Maintenance will be accomplished by the Operator or manufacturer pursuant to the flight manual and operating

handbook as referenced in the Manuals attached as confidential Exhibits An equivalent level of safety will be ach ieved because these small UASs are very limited in size and will carry a small payload and operate only in defined areas for limited periods of time. If mechanical issues arise,

the UAS can land immediately and will be operating from no higher than 400 fee t AGL. As provided in the Aircraft Flight Operations Manual the Operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any

maintenance performed. Moreover, the Operator and manufact urer are most familiar with the

aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent

level of safety. The FAA has granted exemptions for similar operations in Exemptions 11062 through 11067, 11080 and 11110.



## Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

3GLP, INC dba: PRECION FLIGHT DEVICES seeks an exemption from t he following rules:

14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55lbs or less) in geospatial survey. measurement and inspections, motion picture and television operations. For the following purposes: Geographic mapping, delineation, measuring
of terrain , infrastru cture or manmade improvements, Use of sensors on UA for vegetation mapping environmental monitoring, quantification and calculation of area and health of materials, plumes, natural and mineral resources. Video capture for commercial collection and

observ ation to be used in commercials, training videos, documentation, recoding of events,3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 22 environmental observation, counting and classification of physical, natural or mineral resource activity or development.



## Privacy and National Security

All flights will o ccur over private or controlled access pro perty with the property owner’s prior consent and knowledge. Inspection will be of inanimate objects in areas where the owners will have consented to the inspections or otherwise have agreed to allow the UAS and th e Operator

to be in the area where operations will take place.

The size of the UAS, its speed and restricted area of operation do not raise national security

issues.



## Summary

Approval of exemptions allowi ng commercial operations of sUA S ’ s for PRECISION FLIGHT

DEVICES to operate an unmanned aircraft system (UAS) to operate small unmanned aerial vehicle (sUAV), (55lb s or less) f or geospatial survey ing

, measurement and inspections,

c ollection of p hotographs and video and b roadcast of video and telemetry data . f or the following purposes: Geographic mapping, delineation, measuring and 3D modelling of terrain , infrastructure or manmade improvements, Use of sensors on UA for vegetation mapping environmental monitoring, quantification and calculation of area and health of materials, plumes, natural and mineral resources. Video capture for commercial collection and observation to be used in commercials, training videos, doc umentation, recoding of events, environmental observation, counting and classification of physical, natural or mineral resource activity or development. Training to persons individually or belonging to private or public organizations to

increase awareness and improve safety for current and futur e UAS operations within the NAS. special events: including high schools. colleges, professional sports, open air events and fairs

, research, risk management and assessment, motion picture production, surface mi ning, closed set filming, disaster and catastrophe events

, will enhance safety by reducing risk.

Conventional operations, using jet or piston powered aircraft, ladders or placing people in

swamps, on roofs or tall, hazardous or weakened structures, expos es them to higher risks tha n those created by use of a sUAV’S . Conventional aircraft that operate at extremely low altitudes just feet from the subject being inspected and in extreme proximity to people and structures present the risks associated with vehi cles that weigh in excess of 6,000 lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the proje ct location. In contrast, a sUAV weighing fewer than 55 lbs. and powered by batteries

elim inates virtually all of that risk given the reduced mass and lack of combustible fuel carried

on board. The sUAV is carried to the target area and not flown. Th e sUAV will carry no passengers or crew and, therefore, will not expose them to the risks associ ated with manned aircraft flights.

The operation of sm all UASs, weighing less than 5 5 lbs., conducted under the strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein. These lig htweight aircraft operate at slow speeds, close to the ground, and in

areas that are under the control of the customer for the operations and, as a result, are far safer3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 23 than conventional operations conducted with turbine helicopters operating in close pro ximity to the ground and people or the use of individuals to climb the structures to conduct the operations

.

Satisfaction of the criteria provided in Section 333 o f the Reform Act of 2012

– size, weight, speed, operating capabilities, proximity to a irport s and populated areas and operation within visual line of sight and nation al security

– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of PRECION FLIGHT DEVICES ’s

UAS for the Purposes outlin ed herein and are consistent with exemptions already granted, including Exemptions number 11062 thru 11067, 11080, 11109 through 11112, 11114, 11213,
11062, 11857, 11398, 11277, 12515, 12496, 11277, 11356, 11206, 11281, 12516, 12580, 11373A, 11238A, 11239, 11239A, 12505, 12103, 12068, 12208, and 11675.

Sincerely,

3GLP, Inc dba Precision Flight Devices Attn: Stephen M Colligan

Physical Address: 800 E Dimond Blvd, Suite 3

- 650 Anchorage, AK 99515

Mailing Address:

PO Box 874294
Wasilla, AK 99687

SColl igan@PrecisionFlightDevices.com3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 24 

## Appendix A

– Operations and USER Guides

Users Manuals and Guides available to the public, for Specific Aircraft and Controllers used or referenced by PRECISION FLIGHT DEVICES



### Aircraft Link to Manual

DJI Phantom 2 http://dl.djicdn.com/downloads/phantom_2/en/PHANTOM2_User_Manual_v1.4_en.pdf

DJI Phantom 3 https://dl.djicdn.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual__V1.6.pdf
DJI Inspire 1 http://www.dji.com/product/inspire

- 1/info#downloads

DJI Matrice 100 https://developer.dji.com/matrice

- 100/

DJI NAZA MV2 Controlle http://dl.djicdn.com /downloads/nazam

- v2/en/NAZA

- M_Quick_Start_Guide_v1.26_en.pdf

DJI S800 thru S1000 http://www.dji.com/products/prosystem

DJI A2 Controller http://w ww.dji.com/product/a2?www=v1

3DR X8, https://3dr.com/kb/x8/

3DR Iris https://3dr.com/kb/iris/

3DR Solo https://3dr.com/kb/solo/

3DR AeroM https://3dr.com/kb/aero

- m/

3DR Pixhawk Controller https://3dr.com/kb/pixhawk/ Open Mission Planner https://www.dronecode.org/software/compatible

- ground

- control

- stations

PFDCumulUS Similar Configuration to 3DR Aero M, with Pixhawk controller

PFD x

- 450/ PDF 550 DJI, 3DR Controller similar configuration to DJI Phan tom 2/3 3DR Solo

PFD cx

- 850M Similar Configuration 3DR X8 with Pixhawk Controller

Altavian Nova F6500 https://www.altavian.com/Drones
SenseFly eBee https://www.sensefly.com/drones/ebee.html
Topcon Sirus https://www.topconpositioning.com/sites/default/files/product_ files/sirius_solutions_catalog_7010_2162_revb_sm_

Topcon Falcon 8 https://www.topconpositioning.com/sites/default/files/pro duct_files/falcon_8_brochure_7010_2183_reva_sm_0.pdf

Trimble UX5 http://uas.trimble.com/ux5 http://uas.trimble.com/faa

- exemption3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 25 

## Appendix B

- Gen eral Safety and Maintenance Procedures

A) Maintenance Schedule

BEFORE & AFTER EVERY FLIGHT

Check condition of props ( inspect leading and trailing edges for

chips , flex both blades to check for hairline cracks on prop blade

and hub

Check brushless motor sh afts , excessive bearing play, bell housing

and propeller mounts Check motors move freely when spun by hand; Check condition of battery connectors , balance tabs and signal

connections , individual cell voltage

Check camera mounts are secure
When powered up and idling confirm no unusual noise or vibration

from motors.

EVERY 10 FLIGHTS

Visual inspection of shell and other plastic components for

cracking/damage (landing skids, camera mounting plates, etc.); Check tightness of motor retaining scr ews and shell retaining

screws Clean data spring pins and battery contact pads with alcohol and

swab or proprietary electrical contact cleaner and cycle spring pins several times to check for spring weakness and full unimpeded travel Check batteries for number of cycles and discharge per

manufacturers recommendations if required.

EVERY 40 FLIGHTS

Remove upper shell and check state of all wiring

- plugs fully

seated, condition of all solder joints, condition of visible circuit

boards and wiring runs, internals generally clean and no

debris/loose items. At any time, if defects are identified that would compromise flight

operations, communication between sUAS and controller, and/or

camera function , repair or replace parts with Manufacture OEM or better quality parts sUAS. Perform Computer Battery Analyzer (CBA) under load tests on each

battery, log cell and capacity health in database.3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 26 

### B) Record Keeping

A digital record will be kept for all pre

- flight, PIC documentation, flights, flight times, atmospheric conditions, telemet ry, and maintenance records. Precision Flight Devices has standard forms and logs on file as standard operating procedures.



### C) Securing Flight Site



## FSDO Submissions

The sUAS PIC will notify the FAA under the current rules of notification for operation , w ith the appropriate Flight Standards District Office.



## Safety Parameter

i. Before filming occurs, a 100 yard perimeter from the planned flight path will be identified in order to set a “sterile” environment for the operation.

ii. sUAS operator must obtain written or oral permission from all

landowners in sterile environment.

iii. sUAS operator will follow Federal, State and Local rules of notification before operation.

iv. At all times sUAS operator will follow best industry practices for operation and safety and will also carry a minimum of $1mm in general liability insurance in case of any damage to property or persons within the safety parameter

.



## Identify potential obstacles

Photographs of each flight area will be taken as part of mission planning and mission documenta tion. Before each mission , an inventory will be taken for all potential obstacles that must be avoided while in flight. Including:

1. Powerlines

2. Cell Phone Towers

3. Trees

4. Flocks of birds that may take flight

5. Heavily traveled roadways

6. Utility wires

7. Elevated structures

8. At least 5 nautical miles from the nearest airport or helipad.3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 27 

### D) Pre

- Flight Checklist



## Take Off Location/ “Home”

The sUAS will mark its take off location as a safe area to return to should the sUAS lose signal with the control or if the pilot si gnals

the craft to return to its “home” location.

Take off location will be in an area with a 25ft radius with no obstructions, maintaining said radius vertically 200ft.

The sUAS will take off and land in the same location.

GPS Altimeter will be marked as 0’ elevation



## Flight Canceling Events

All flights will be cancelled until the area is cleared if any of the

below occur: Police activity in the area Low flying aircraft in the area Medical/News Helicopters active in the area Wind exceeding 2 5 mph Any emer gency requiring emergency services occurs within the

sterile environment PIC is unable to complete flight without losing visual of the sUAS Any precipitation Heavy bird presence in the area that could cause a mid

- air

collision. Any defects or damage found during preflight exam to the UAS or communications equipment.



## Physical Inspection

Before each flight the sUAS will be checked to ensure that it is safe for flight. Battery voltage will be checked to ensure it is >75% Blades will be inspected to ensure th ey are tightened and free of damage Camera mount and gimbal will be inspected to ensure it is fully

attached and operating. sUAS will be checked for any damage that may have taken place

in transit.

The sUAS will be tested at a low altitude to ensure all co ntrols are responding correctly. Battery checked for damage that could affect its charge If any party of the inspecting shows a damaged part or parts, the

sUAS is deemed non

- usable and must be inspected b y a factory trained technician.3GLP, Inc. dba Precision Flight Devices, 800 E Di mond Blvd, Suite 3

- 650, Anchorage, AK 99515 www.PrecisionFlightDevices.com 800.756.5680 Page 28 

## Post Flight Inspect ions/Checklist

After each flight, the sUAS will be thoroughly inspected for any damage that occurred in flight. Body inspected for any damage Blades visually checked for any damage at all Battery checked for damage



### E) Mid

- Air Safety Protocol

Max Speed

Acc ent : 1. 10m/s

Decent : 4m/s Flight Speed : less than

- Multi Rotor 1 5 m/s

, Fixed Wing 21 m/s



### Altitude

The sUAS is never to exceed 400ft



### Emergency

If it appears that the UAS, any property or humans are at risk, the sUAS will be grounded immediately to a safe location.



### Visual Line of Sight

The pilot must keep the sUAS within eyesight at all times unassisted by any technology.



### F) 

### Participation by non

- pilot staff

All staff involved in the production or filming using the sUAS will

consent to maintain a safe distance of at least 30 ft during the operations

.