Regulations from which the exemption is requested:

14 CFR Part 21 14 C.F.R. § 45.23(b) 14 CFR § 61.113 (a) & (b) 14 C.F.R. § 91.7 (a) 14 CFR § 91.9 (b) (2) 14 C.F.R. § 91.103
14 C.F.R. § 91.109 14 C.F. R. § 91.119 14 C.F.R. § 91.121 14 CFR § 91 .151 (a) 14 CFR § 91.203 (a) & (b) 14 CFR § 91.405 (a) 14 CFR § 407 (a) (1) 14 CFR § 409 (a) (2) 14 CFR § 417 (a) & (b) 3

Unmanned Aerial System Description

Chaetura , LLC is petitioning for exemption to utilize the following Unmanned Aerial Systems ( UAS ) :

DJI Phantom 3 Pro, DJI Inspire 1, DJI Spreading Wings S800, DJI Spreading Wings S900, DJI Spreading Wings S1000, DJI M100, DJI Agras MG

- 1, Cinestar 8 Octo, Altavian Nova F6500, AgEagle, 3DRobotics X8, 3DRobotics Iris, 3DRobotics Solo, SenseFly eBee, SenseFly eXom, Dragan FlyerX4

- ES, Trimble UX5, PrecisionHawk Landcaster, ATI AG550, AGDrone, Event 38 E384, Falcon Fixed Wing, Falcon Hover, Pulse Vapor, Stark Aerospace Arrowlite , Latitude Engineering HQ

- 40 Hybrid Plane, Aero Vironment Puma, Aero Vironment Shrike, AerialTronics Altura Zenith

These UAS all weigh less than 55 lbs

. , have built in capability to limit the height it flies abov e ground, to limit the radius of the distance it flies from the operator, and includes a no fly zone feature. Each system also has the failsafe function of the autopilot system, which means when the communication between the

main controller and the transmi tter is lost, the system will automatically trigger Return to Home and will land safely.

Granting an Exemption Would Serve the Public Interest In the absence of a UAS, many of the proposed a ctivities would have to be carried out by a helicopter, fixed wing aircraft, human surveyor or a lineman climbing a tower. All of these conventional methods involve a risk to human lives and property that is clearly higher than risks to human lives and pro perty posed by the utilization of UAS.

Our UAS are battery powered and therefore creates no noxious emissions hazardous to the environment. Further, as a battery powered vehicle the noise levels are substantially lower than any internal combustion engine driven aircraft.

With respect to wildlife survey operations, UAS derived data can be utilized for more effective wildlife management and reduced potential harm to human surveyors. This can be of substantial benefit for wildlife managers, particularly for threatened and endangered species

.

Survey, mapping, and inspection of energy infrastructure facilities utilizing UAS technology is substantially more cost effective than the conventional methods to accomplish these tasks.Operational SAFETY Assurances

Chaetura proposes the following operational limitations to achieve an equivalent or higher level of safety than under the current regulatory structure, particularly in comparison to the use of manned aircraft.

1. All operations will be carried out with strict adherence to the operating procedures outlined in the Pilot’s Operating Handbook (POH) and the manufacturer’s user manual (Attachment A & B,

resp ectively). The POH is organized similar to a manned aircraft POH and includes the following sections: a. General description, specifications, and warnings b. Limi tations c. Emergency Procedures d.

Normal Procedures e. Performance f. Weight and Balance/Eq uipment List g. Air Vehicle and Systems Description h. Handling, Service, and Maintenance i. Supplements

2. The UA will weigh less than 55 lbs.

3. The UA will operate at a true airspeed maximum (VNE) of 100 mph (<80 knots).

4. Minimum crew for e ach operation will consist of the UA Designated Pilot in Command (PIC) and at least one Visual Observer (VO). The PIC and VO will be able to communicate verbally at all times during the flight and will not exchange roles during the flight. Electronic messa ging or texting is not permitted during flight operations. The PIC will ensure that the VO can perform the required duties of the VO.

5. The PIC will hold either an airline transport, commercial, private, recreational, or sport pilot certificate

and a cu rrent 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 will also meet the flight review requirements specified in 14 CFR §61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

6. Flights will be operated within visual line of sight (VLOS) of the PI C and VO at all times. Chaetura

u nderstands that definition of VLOS is human vision unaided by any d evice other than corrective lenses.

7. The primary responsibility of the VO will be to enhance the safety of flight operations by verbally communicating potentially unsafe observations to the PIC. Such conditions may include, but are not limited to, con flicting aircraft, hazardous terrain, features, or weather, UA approaching VLOS limits or altitude limits, assisting the PIC in monitoring battery voltage, and advising the PIC if non

- participating personnel move within a potential danger zone. VO’s will b e familiar with the UAS normal and emergency procedures and aircraft limitations in sufficient detail as to provide the PIC with recommended

corrective actions.

8. All flights will be conducted under a strict battery management regime that alerts the operator to end flight at a pre

- determined battery capacity. If the PIC exceeds this limit, the UAS will autonomously return to the departure point and land upon reac hing the first critical battery level (first alert) and will land immediately upon reading the second critical battery level (second alert).

9. Flights will be operated at an altitude of no more than 400 feet Above Ground Level (AGL).

10. All opera ting documents will be accessible to the PIC at the ground control station during UAS operations. Operating documents will include the current POH and a copy of the FAA’s Exemption, if granted. If a discrepancy exists between the various operating document s, the FAA’s Exemption, the Exemption will take precedence. The POH will be updated as necessary. Such updates will be tracked.11. A safety briefing will be performed prior to each day’s flights consisting of all the day's’ flight

operations. All part ies involved in the flight operations will participate in the safety briefing.

12. The PIC will conduct a pre

- flight inspection for the UAS. The pre

- flight inspection will account for all systems to insure that the UAS is in a condition for a safe flig ht. As a minimum, the preflight inspection will follow the checklist procedures in the POH. If the pre

- flight inspection reveals a condition that may affect the safe operation of the UAS, the aircraft will not be operated until necessary

maintenance has be en completed.

13. In the event of an emergency or other unpredicted obstacle to the completion of a flight, the PIC will abort the flight in the safest manner possible.

14. Chaetura will not permit a PIC to operate the UAS unless the PIC demonstra tes the ability to safely operate the UAS safely and competently within the framework of the measures outlined herein and the POH. This will include normal and emergency procedures and maintaining appropriate distances from persons, vessels, vehicles and s tructures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR §61.51(b).

15. The PIC and VO will have been trained in operation of UAS and receive current information regarding operation of the UA S

.

16. PIC and VO training and evaluation flights will only be conducted during dedicated training sessions. During such sessions, the PIC will operate the UA S a manner consistent with 14 CFR §91.119 by maintaining the prescribed distance from non

- participants.

17 . All aircraft utilized as a part of this request will be registered and subsequently assigned a serial number in accordance with 14 CFR part 47 and display identification markings in accordance with 14 CFR part 45, subpart C. N

- number markings will be as large as practicable.

18. Chaetura will conduct routine inspections of the UA to ensure that it is in condition for safe operation. As a minimum, inspections will be conducted as per the POH and as per manufacturer recommendations. Additional inspectio ns will be completed as deemed necessary. We will comply with all safety bulletins issued by the manufacturer.

19. Chaetura will conduct maintenance on the UA S as necessary. Maintenance procedures will follow manufacturer’s recommendations regarding re placement, overhaul, and life limited components.

20. After maintenance or alterations that affect the operational or flight characteristics of the UA S , a test flight will be conducted to determine that the UA S is properly functioning prior to resuming c ommercial operations. Flight tests will be conducted by a PIC and a VO and will remain at least 500 feet from other

non

- participants. Further, the flight test will be conducted in a manner so as not to pose an undue hazard to persons and property.

21. Chaetura will also obtain a Certificate of Waiver or Authorization (COA) from the FAA Air Traffic Organization (ATO) prior to conducting operations within the NAS.

22. No UA flights will be conducted at night and all flights will occur under Visual Meteorological Conditions (VMC).

23. The PIC will ensure that the UA remains clear of and gives right

- of

- way to all manned aviation operations.24. The PIC will not operate the UA from a moving device or vehicle.

25. The UA S will not be operated within 5 nautical miles of an airport reference point (ARP) unless a letter of agreement with that airport’s management is obtained or it is otherwise permitted by a COA

issued to Chaetura.

26. The UA S will be operated in a manner that maintains at least a 500 foot clearance from all nonparticipating persons, vessels, vehicles and structures except in the case of the following conditions: a.

Barriers are present to protect non

- participating persons in the event of an accident. Chaetura will ensure

that non

- participating persons utilize these protective barriers. If a nonparticipating person leaves a barrier

and is within 500 feet of the UA S , flight oper ations will be terminated in a manner that ensures the safety

of non

- participating persons. b. The owner or controller of any vessels, vehicles, or structures has granted permission to operate closer than 500 feet to those obstacles and the PIC has complet ed a safety assessment of the proposed operation and determined that the operation could be completed safely.

27. Flight operations will only be conducted over property where the permission is granted by the property owner or otherwise authorized repre sentative.

28. The UAS automatically determines its failsafe return

- to

- home position upon liftoff. If the UAS loses communications with the remote controller, it will return to a liftoff location and land autonomously.

29. Chaetura will report any i ncident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents will be reported to the National Tr ansportation Safety Board (NTSB).

SPECIFIC EXEMPTIONS REQUESTED In pursuit of this petition the following exemptions are requested:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 C.F.R. 91.203 (a) (1) Subpart H, entitled Airworthines s Certificates, establishes the procedural requirements for the issuance of

airworthiness certificates as required by FAR §91.203 (a) (1). Given the size and limited operating area

associated with the aircraft to be utilized by Chaetura an exemptio n from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft fro m the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that th e UAS operated without an airworthiness certificate in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate

with out the restrictions and conditions proposed.

The UAS to be operated hereunder is less than 55 lbs. fully loaded, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured a nd designated area. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monitored by the operator. These safety enhancements provide a greater degree of safety to the public and property owners than conventional oper ations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H.Lastly, there is no credible threat to national security posed by the UAS, due to its size, speed of

operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. §9 1.9 (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 required by §21.5 of this chapter, unless there i s available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

The UAS, given its size and configuration has no ability or place to carry such a flight ma nual 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 control point wh ere the PIC will have immediate access to it.

14 C.F.R. §91.103: Preflight Action This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. These actions include the following:

a. For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot i n command has been advised by ATC;

b. For any flight, runway lengths at airports of intended use, and the following takeoff and landing

distance information:

1. For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff

and landing distance data is required, the takeoff and landing distance data contained therein; and

2. For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature.

As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be

needed. The PIC will take all a ctions as stated in the POH in Section 4 under Normal Procedures including but not limited to reviewing weather, flight battery requirements, 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 civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls.

UAS and remotely piloted aircraft, by their design do n ot have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio signals. The equivalent level of safety is provided by the fact that neither a pilot nor passengers will b e carried in the UA and by the small size, weight, and generally slow speed of the UAS.

14 C.F.R. §91.119: Minimum Safe Altitudes Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be ope rated 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 request is for a both fixed wing and rotary UAS and the exemption requests authority to operate at altitudes up to 400 AGL an exemption may be needed to allow such operations. As set forth herein, theUAS will never operate at higher than 400 AGL It will only be operated in a controlled environment,

where structu res, vessels, vehicles, and non

- participating people will not be exposed to operations.

The equivalent level of safety will be achieved given the small size, low weight, and slow speed of the UAS as well as the controlled environment where it is operated . No flight will be initiated without the permission of the property owner or authorized representative. Unlike conventional aircraft, the UAS requires no flammable fuel, a safety enhancement at low altitude. Further, since the UAS will be operated |at 400 AGL or less, it will maintain separation from manned aircraft that are required to comply with

Section 91.119.

14 C.F.R. §91.121 Altimeter Settings This regulation requires each person operating an aircraft below 18,000 feet MSL to maintain cruising

a ltitude by reference to an altimeter that is set to a particular barometric pressure (altimeter setting) or the elevation of the departure airport.

A ll altitude readings displayed on the Ground Control Station are in AGL from the departure site. In order comply with the limitations specified herein to maintain an altitude below 400 feet AGL, it is appropriate

for th e altimeter to display in AGL instead of MSL thereby maintaining separation from manned aircraft and achieving an equivalent level of safety.

14 C.F.R. §91.151(a) and (b): Fuel Requirements for Flight in VFR Conditions Section 91.151 specifies fuel res erve minimums for airplanes and helicopters. Specifically, 91.51 (b) states that no person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of i ntended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

Since our UA S are battery powered and lack a combustion engine, there is no conventional fuel consumption. An equivalent level of safety will be achieved by landing the aircraft when the battery power, as monitored at the ground control station, rea ches 30% of the capacit y of a fully charged battery. A further safety feature our UAS will automatically return to its departure point with no PIC interaction required if the battery voltage falls below 20% of the capacity of a fully charged battery.

14 C.F.R. §91.2 03 (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 appropriate and current ai rworthiness certificate. . . .

2. An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second duplicate copy (pink) of the Aircraft Registration Application as provided for in §47.31(b), or a registrat ion certificate issued under the laws of a foreign country. b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.

As previously discussed, an exemption is sought regarding the requirement to acquire an airworthiness certificate. Further, the UAS fully loaded will weigh less than 55 pounds and is operated without an onboard pilot. As such, there is no ability or place to carry a registration certificate or to display it on the UAS. An equivalent level of safety will be achieved by keeping the registration certificate at the ground control point whe re the PIC will have immediate access to it.14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections

These regulations cover maintenance, preventative maintenance, and aircraft alterations. In summary for VFR aircraft, an d not including all exceptions, it requires the following:

1. Annual inspections or 100

- hour inspections (for commercial operations) with approval for return to service by a person authorized by §43.7.

2. A test flight by an appropriately rated pilot after repairs or alterations that may have appreciably changed the aircraft’s flight characteristics have been made

3. Logging of all maintenance performed according to particular standards

These sections, collectively part of Subpart E, and Part 43 only apply to aircraft with an airworthiness certificate. As previously discussed, an exemption is sought regarding the requirement to acquire an airworthiness certificate. However, an equivalent level of safety will be achieved by implementing the concepts of these sections as follows:

1. Inspections will be performed at intervals recommended by the POH and the

manufacturer.

2. A test flight will be performed after any maintenance or alteration is performed that may

a ffect the UA S flight characteristics. The test flight will be performed prior to return to commercial service by an appropriately rated and experienced PIC.

3. All maintenance will be logged.

CLOSING

Chaetura, LLC appreciates the opportunity to submit this petition for exemption to the Federal Aviation Administration. We have endeavored to provide the appropriate information required based on guidance from the FAA’s website. If there are any questions or we can provide further information, please contact Sarah Hammond, PhD, owner, Chaetura, LLC.