Page 1

Anthony J. Pucciarella

ALARIS

PO Box 1835 Lusby, MD 20657

240

- 538

- 8444 Tony@TeamAlaris.com

1 January 2016

United States Department of Transportation
Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Re: Petition for Grant of Exemption Pursuant to Section 333 of the FAA Modernization and
Reform Act of 2012

To Whom It May Concern :

Pursuant to Section 333 of the Federal Aviation Administration Modernization and Reform Act of 2012 (the Ref orm Act) and 14 C.F.R. Part 11, iSkyDrive (hereafter referred to as “ ISKYDRIVE” ) hereby applies for an exemption from the listed Federal Aviation Regulations (FARs) to allow commercial operation of the following small Unmanned Ai rcraft Systems (UAS) to conduct aerial data collection and training provided such operations are conducted within the conditions outlined in this exemption request or as established by the FAA :

 UAV Solutions (UAVS) Phoenix 30, Phoenix 60, and Talon 120LE

 3 DR Iris+, and Solo

 DJI Inspire 1, Phantom 3, S

- 900 and S

- 1000

ISKYDRIVE respectfully submits that this Petition for Exemption qualifies for approval, as the

FAA has previously issued grants of exemption in circumstances similar to those presented in this petition.

In addition to this Petition for Exemption, Alaris will also submit s upporting documents (referred to as “Operating D ocuments” in this petition ) on behalf of ISKYDRIVE :

Alaris submits some of these documents a s confidential material under separate cover pursuant to 14 C.F.R. § 11.35(b) since the document s contain confidential commercial and proprietary
information that ISKYDRIVE does not intend to share with others. The information contained i n th ese document s is not generally available to the public and is protected from release under the Freedom of Information Act, 5 U.S.C. § 552 et seq.Page 2

Petitioner Background and Description of Proposed Operations

ISKYDRIVE is a Southern Maryland

- based, small business launched in 2015 that offers a range of services specializing in UAS safety awareness, training, and pilot services. ISKYDRIVE intends to enhance these services by providing outdoor real

- world training to support saf e operations by their customers. ISKYDRIVE CEO and Owner Ronney Miller has been a certified FAA pilot since 2006 and has over 2,500 flight hours in military and commercial UAS.

As described in the following paragraphs, an approved exemption would permi t operations of
the requested systems under controlled conditions in limited airspace with the approval o f cooperating property owners. These operations would provide improved safety over the existing means of conducting the same operation with larger mann ed systems.

T his petition is intended to allow ISKYDRIVE to conduct the following commercial UAS operations:

- Aerial photography / video for public / private use including land survey s, architecture,
real estate

, engineering

, and other related professional activities.

- Aerial video / photography for public / private use including television, public events, and news gathering.

- Aerial inspection/photography of residential/commercial structures under contract with
the owners or local government authority.

- Aerial inspection/photography of residential/commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers.

- Aerial video/photography t o assist with search and rescue operations in cases of an emergency or natural disaster when requested by local authorities or government organizations.

- T raining public/private individual s that have interests in the use and application of UAS
to support safe operation s that enhance the safety of the National Airspace System (NAS) as well as for the protection of persons and property.

As described in the following paragraphs, an approved exemption would permit operations of
the requested multi

- rotor UAS under controlled conditions in limited airspace with the approval

o f cooperating property owners.

In accordance with 14 C.F.R. § 11.81(a), ISKYDRIVE provides the following information in support of its Petition for Exemption.

The contact information for Petitioner is as follows:

Name: ISkyDrive

Attn: Ronney B. Miller, CEO/Owner
Address: 1425 K Street, NW Suite 350

Washington, DC 20005 (202) 854

- 1906Page 3

Regulations F r om W hich E xemption I s R equested

91.7 (a)

– Civil Aircraft Airworthiness

91.9 (c), 45.23(b) , and 45.27 (a)

– Aircraft Marking and Identification Requirements 61.101 (e) and 61.113

– Private and Recreational Pilot Privileges and Limitations 91.9 (b) (2)

– Civil Aircraft Flight Manual in the Aircraft 91.203 (a) and (b)

– Certifications required for civil aircraft

91.103

– Preflight Action

91. 109 (a)

– Flight Instruction

91.119 (b) and (c)

– Minimum Safe Altitudes

91.121

– Altimeter Settings 91.151 (a)

– Fuel Requirements for Flight in VFR Conditions 91.405 (a) , 91. 407 (a) (1) , 91. 409 (a ) (1) and (2) , 91. 417 (a) & (b)

– Maintenance Inspections

The s ystem s requested in th is exemption represent both fixed

- wing and multi

- rotor UAS . All systems requested weigh less than 20 pounds

– considerably less than the 55 pound requirement that defines s mall UAS (sUAS)

. ISKYDRIVE will operate th ese system s with in Visual

Li ne of S ight (VLOS) of the Pilot and Visual O bserver. All UAS will operate at speeds less than 87
knots and some ha ve the ability to hover. Area of operations will be over private property with owner permission or public property with permission from the appropriate officials

. ISKYDRIVE operations will not create a hazard to users of the national airspace system or the public.

Utilization of the proposed UAS is of public in terest and safety. The proposed UAS are less intrusive than manned helicopter s and ha ve less of an impact on the environment. All systems requested are battery powered and energy friendly. The system s require minimal distance for launch and recovery from the operat ion area which minimizes transit time s a s well as the possibility of encounters with manned aircraft

.

ISKYDRIVE ’ s proposed operations in this Petition for Exemption qualify for expedited approval pursuant to Section 333 of the Reform Act, as each of the statutory criteria and relevant factors are satisfied. Approval is Warranted Based on the UAS’s Size, Weight, Speed , and Operational Capability. The FAA has already determined that similar systems chosen meet the requirements
of Section 333 of the Reform Act.

Description Of Proposed Systems

The Phoenix 30 Air Vehicle (AV) is a battery operated multi

- rotor with an a irframe weight of 10 pounds (including battery and payload). The P hoenix 30 AV measures approximately 36 inches
in diameter (including propellers), and operates on 900 MHz

.

The Phoenix 60 AV is a battery operated multi

- rotor with an airframe weight of 17.4 pounds (including battery and payload). The P hoenix 60 AV measures approximately 47 inches in
diameter (including propellers), and operates on 900 MHz and 2.4 GHz

.Page 4

The Talon 120LE AV is a fixed

- wing, lightweight UAS with an airframe weight of 17 pounds fully loaded (including battery and payload). It has a wingspan of 10 feet and operates on 900 MHz
and 2.4 GHz.

The 3DR IRIS+ and Solo AV s are battery operated quadcopter s with air frame weight s between

3 to 4 pounds (including battery and payload). The y measure approximately 3 0 inches in
diameter (including propellers), and operate on 900 MHz and 2.4 GHz

.

The DJI Inspire 1 is a battery operated quadcopter with an airframe weight of 6.5 pounds (including battery and payload). The Inspire 1 measures approximately 23 inches in diameter (including propellers), has a maximum operating ground speed of 43 knots, and operates on 2.4

GHz

.

The DJI Phantom 3 is a battery operated quadcopter with an airframe weight of 3 pounds (including battery and payload). The Phantom 3 measures approximately 23 inches in diameter (including propellers), has a maximum operating ground speed of 31 knots, and operates on 2.4

GHz

.

The DJI S 900 is a battery operated multi rotor with an airframe weight of approximately 18 pounds (including battery and payload). The S900 measures approximately 35 inches in
diameter (including propellers), has a maximum operating ground speed of approximately
35kno ts, and operates on 2.4 GHz

.

The DJI S1000 is a battery operated multi rotor with an airframe weight of approximately 25 pounds (including battery and payload). The S1000 measures approximately 41 inches in
diameter (including propellers), has a maximum operating ground speed of approximately 35knots, and operates on 2.4 GHz

.

All of the proposed UAS operate safely after experiencing certain in

- flight contingencies or
failures and u tilize an auto

- pilot system for stability and control. Th e systems are also able to respond to a loss of GPS or a lost

- link event with a pre

- coordinated, predictable, automated maneuver. These safety features provide an equivalent level of safety compared to a manned aircraft performing a similar operation and mitigate the risk of command and control contingencies

.

Previously I ssued FAA E xemptions F or Similar Operations

The FAA has previously issued grants of exemption in circumstances substantially similar to those presented in this Petition for Exemption, including, but not limited to:

- Exemption No. 1 21 09 ( Docket No. FAA

– 2015

– 1 12 2 ) to UAV Solutions, Inc. to operate the Phoenix 30 UAS for aerial data collection

.Page 5

- Exemption No. 1 2110 ( Docket No. FAA

– 2015

– 1 120 ) to UAV Solutions, Inc. to operate the Phoenix 60 UAS for aerial data collection

.

- Exemption No. 13743 ( Docket No. FAA

– 2015

– 3796 ) to UAV Solutions, Inc. to operate
the Talon 120LE UAS for aerial data collection

.

- Exemption No. 12 443 (Docket No. FAA

– 2015

– 1 451 ) to Precision Resource Management Imagery, LLC to operate the 3DR IRIS+ UAS for aerial photography, videography, inspections, and monitoring

.

- Exemption No. 11394 (Docket No. FAA

– 2015

– 0160 ) to Cirrus Exploration Company for DJI Inspire 1 (and other UAS) operations to conduct flight inst ruction, commercial aerial work flight operations, student instruction, aerial photography and survey, and power line or pipeline patrol.

- Exemption No. 11778A ( Docket No. FAA

– 2015

– 0591 ) to Cloud9Drones LLC to operate the Phantom 3 and Inspire 1 to conduct aerial inspections of towers/tall structures for multiple industries, and videography for film and marketing.

- Exemption No. 11297 (Docket No. FAA

– 201 4

– 0957 ) to Aerial Media Systems to operate the DJI S1000 to conduct video, images, and surveying of perso ns and property for
commercial broadcast.

Approval I s Warranted Based O n T he Operational Restrictions I n ISKYDRIVE ’ s Operating

Documents

ISKYDRIVE ’s operating documents contain the necessary procedures and limitations required to safely pe rform the proposed operations. To assist the FAA in making a safety assessment of

ISKYDRIVE ’s proposed operations, the following summary is provided which includes the
limitations and conditions that ISKYDRIVE will adhere to, and which will ensure an equiv alent or higher level of safety to operations conducted under current regulatory guidelines by manned
aircraft :

1. Operations authorized by grant of this exemption are limited to the proposed

ISKYDRIVE UAS which weigh less than 55 pounds including payload. Proposed operation of additional aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.

3. All f li ghts will be conducted within VLOS of the Pilot and Visual Observer in day Visual Meteorological Conditions (VMC). This requires the PIC to use vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman
medical c ertificate or U.S. driver’s license.Page 6

4. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles. Flights under special visual flight rules (SVFR) are not authorized.

5. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA

- publis hed aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the airport management must be made available to the
Administrator or any law enforcement official upon request.

6. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that for at least five minutes or with the

reserve pow er recommended by the manufacturer if greater.

7. The PIC may not operate the UAS from any moving device or vehicle.

8. Flights will be operated at or below 4 00 feet AGL.

9. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.

10. The UA must remain well clear and give way to manned aviation operations at all times.

11. The speed of the UAS will not exceed 87 KTS (100 MPH)

. In no case will the Air Vehicle be operated at airspeeds greater than the maximum airspeed recommended in the Operations Manual

.
12. The operating documents and this exemption must be accessible to the PIC during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be followed. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present

u pdated and revised documents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator
determines t hat any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption.

13. The operator is responsible for maintaining and inspecting the UAS to ensure that it i s in a condition for safe operation and must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the UAS. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

14. P rior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition for safe flight. If the inspection reveals a condition that affects the safePage 7

operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be safe for flight

.

15. Minimum crew for each operation is a Pilot and Visual O bserver (VO)

. The Air Vehicle must be operated within the visual line of sight (VLOS) of the PIC and VO at all time s. The VO may be used to satisfy the VLOS requir ement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the duties required
of the VO

16. Any PIC operating under this exemption must hold either an airline transport, commercial, private, recreational, or sport pilot certificate.

17. The PIC operating under this exemption must hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the Distric t of Col u mbia, Puerto Rico, a territory, a possession, or the Federal government.

18. The operator may not permit any PIC to operate UAS unless the PIC demonstrates the ability to safely operate the system in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification

, flight hours

, and currency must be logged in a manner consistent with 14 CFR § 61.51(b).

19. Flights will only occur over p rivate property with owner approval or public property
with permission from the appropriate officials (all required permissions and permits will be obtained from territorial, state, county or city jurisdictions, including local law enforcement, fire, or ot her appropriate governmental agencies)

.
20. Flight operation s will not occur within 5 00 feet of personnel in the designated area that are not part of the specific operation.

21. PIC will brief all involved personnel on flight operations and applicable safety procedures prior to flight operations . A single brief will suffice for multiple flights unless there are personnel or operational changes.

22. All operations shall be conducted in accordance with the issued Certificate of Waiver or Authorization ( COA )

.
23. Pilot and Visual Observer will hav e been trained in UAS operations

.

24. In case of “ loss o f communication /link ” or “ loss of GPS ”

, the proposed UAS will have the capability to return to a pre

- determined point within the prescribed area of operations and land.

25. All Air Vehicles operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as pract icable.Page 8

14 CFR 91.7(a)

- Civil Aircraft Airworthiness

Since there wi ll be no airworthiness certificate issued for the UAS, Petitioner seeks an exemption from 14 CFR § 91.7(a), which requires that “n o person may operate a civil aircraft
unless it is in an airworthy condition .” T he FAA has previously determined that for the purposes of this exemption

, the pilot may determine the aircraft is in an airworthy condition prior to flight. The operating documents contain procedures which direct the PIC to determine whether the aircraft is in a condition safe for flight, and an exemption from § 91.7(a) is therefore
warranted

14 CFR 91.9(c), 45.23(b) and 45.27(a)

- Airc raft Marking and Identification Requirements

91.9(c), Civil Aircraft Flight M anual, Marking and Placard requirements, provides that: No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with Part 45 of this chapter.

45.23(b), Markings of the Aircraft, states:
When marks include only the Roman capital letter "N" and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near
each entrance t o the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words "limited," "restricted," "light

- sport, "experimental," or "provisional," as applicable.

45.27(a), Rotorcraft, states: Each operator of a rotor craft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required by § 45.23.

In a prior grant of exemption under Section 333 of the Reform Act, the FAA determined that exemption from these requi rements was warranted provided that the aircraft have identification markings in accordance with 14 C.F.R Part 45, Subpart C if the markings are as large as practicable. All Air Vehicles flown by Petitioner will bear N

- number markings that are as large as practicable in accordance with 14 C.F.R. Part 45, Subpart C.

14 CFR § 61.101 (e) and 61.113

- Recreational and Private Pi lot Privileges and Limitations

Sections 61.101 (e) and 61.113 limit Recreational and P rivate pilots to non

- commercial operations.

The FAA recently determined that holders of recreational and sport pilot certificates would have adequate aeronautical knowledge to pilot a UAS. Accordingly, because these individuals would also be subject to security screening by the Department of Homel and Security (DHS), the FAA determined that holders of recreational and sport pilot certificates would be qualified to

serve as the PIC for UAS operations (see Exemption 11213

, Docket No. FAA

- 2014

- 0642 ).Page 9

Petitioner will operate on private property away from persons and property not involved in the operation and will require all PICs to be thoroughly trained in the unique aspects of UAS flight. As set forth in the operating documents, pilots will have experience not only in UAS operations generally but have logged flight time in the specific make and model used for the operations before they are permitted to participate in commercial flights on behalf of the Petitioner . The pilot qualification, training, and currenc y requirements in the operating documents ensure that
Petitioner’s pilots are competent and proficient in the UAS they are operating. The Petitioner's training and qualification requirements are consistent with those contained in prior FAA issued
grants o f exemption, and wi ll provide a high level of competency and proficiency for its pilots and will ensure at least an equivalent level of safety.

14 C.F.R. § 91.9 (b) (2)

- Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides that n o person may operate a U.S.

- registered civil aircraft f or which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved airplane or Rotorcraft Flight Manual, approved manu al material, markings, and placards, or any combination thereof.

Given the size of the proposed UAS Air Vehicle s and the general nature of UAS operations, the Operations and Maintenance M anual for flight s conducted under this exemption will be located

in proximity t o the PIC and Visual Observer. An equivalent level of safety is provided by keeping the manual on the ground for immediate access by the crew.

14 C.F.R. § 91.103

- Preflight action

This regulation requires each pilot in command to take certain actions before flight to e nsure the safety of flight.

Petitioner requests an exemption from 14 C.F.R. § 91.103 since an FAA approved flight manual will not be provided for the aircraft. The p reflight procedures in the Operating Documents will ensure that the UAS is in an airworthy condition prior to flight and thereby provide an equivalent level of safety. The PIC will take all actions prior to initiating flight including reviewing weather, fl ight batter y requirements , landing and takeoff distances, and aircraft performance data

.

The PIC will complete a series of checklists designed to identify any defects or inoperable components, which cover pre

- flight, take

- off, landing and post

- flight procedures

. Petitioner's

O perating D ocuments will be kept at the ground control station and will be accessible to t he PIC at all times while operating the UAS.

14 C.F.R. §91.109 (a)

- Flight instruction

Section 91.10 9 (a) 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.Page 10

Like other unmanned systems, t he proposed UAS do not have fully functional dual controls so the Petitioner requests an exemption from this rule. Flight control is accomplished through the

use of a remote controller that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls and for flight instruction in experimental aircraft. An equivalent level of safety will be provided si nce neither a pilot nor passengers will be carried in the aircraft and by the limited aircraft size

, speed , and operational area

.

14 C.F.R. §91.119

- Minimum safe altitudes

Petitioner requests an exemption from the minimum safe al titude requirements of § 91.119

, which state:

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other tha n congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or

structure.

As this exemption is for s mall UAS and seeks authority to operate at altitudes up to 400 AGL

, the Petitioner requests an exemption t o allow such operations. As set forth herein, the proposed UAS will not operate above 400 AGL. An equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where operations occur . No flight will be taken without the permission of the property owner or appropriate official.
Because of the advance n otice to the property owner and participants

, all affected individuals will be aware of the planned flight operations as set forth in the Petitioner’s Operating

Documents

.

The proposed UAS Air Vehicle s all weigh less than 5 5 pounds each fully loaded and carr y no pilot or passengers, explosive material or flammable liquid fuels

. Compared to flight operations
with manned aircraft or rotorcraft weighing far more , the risk associated with the proposed operations is far less than those presented by c onventiona l aircraft operating at or below 500 AGL performing similar operations

. Ad dition ally , the proposed low

- altitude operations of the

s mall UAS will ensure separation from manned aircraft that must comply with Section 91.119.

14 C.F.R. §91.121

- Altimeter Se ttings

This regulation requires that each person operating an aircraft shall maintain the cruising altitude by reference to an altimeter that is set when operating below 18,000 MSL to t he elevation of the departure airport or an appropriate altimeter sett ing available before departure (for the case of an aircraft not equipped with a radio ).Page 11

The FAA has stated previously that an equivalent level of safety to the requirements of 14 C.F.R. § 91.121 can be achieved in circumstances where: (1) the UAS will be operated below 400 feet AGL or below, (2) within VLOS, (3) where GPS based altitude information is relayed in real time to the operator at a ground

- based on

- screen display and, (4) where prior to each flight, a zero altitude initiation point is established for the PIC to conf irm accuracy of the onboard GPS (see Exemption No. 11062 , Docket No. FAA

- 2014

- 0352 ).

The UAS that the Petitioner intends to use for the proposed operations meet all these operational characteristics. Additionally, the operating do cument s require the PIC to calibrate the aircraft's GPS prior to each flight. As the FAA has determined in circums tances similar to
this Petition , Petitioner's UAS and the safety mitigation procedures contained in the operating documents ensure that an eq uivalent level of safety will be achieved, and a grant of exemption to the requirements of § 191.121 is therefore appropriate.

14 C.F.R. § 91.151(a)

- Fuel Requirements for Flight in VFR Conditions

Section 91.151 (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 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The batter ies of some of the proposed UAS provide less than 30 minutes of flight time to the Air
Vehicle

. To meet the 30 minute reserve requirement of 91.151 would prevent flight operations for these systems

, therefore an exemption from this rule is req uired . Due to the proposed
altitude limitations and the area of operation s , a longer time for flight in daylight V FR operations is reasonable. The FAA has approved similar exemptions from the fuel requirements
of § 91.151(a) for flight in day VFR conditions

. T he FAA determined that a requirement prohibiting the PIC from beginning a UAS flight unless (considering wind and forecast weather conditions) there was enough available power fo r UAS to operate for the intended operational time and to operate after that for at least five minutes or with the reserve power recommended by the manufacturer if greater, would ensure an equivalent level of safety to the
fu el requirements of § 91.151(a) (see Exemption No. 11213 ). Petitioner's operating documents impose this same requirement an d an exemption from §91.151(a) for flight in V FR conditions is therefore appropriate.

14 C.F.R. §91.2 03 (a) and (b)

- 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 a n appropriate and current airworthiness certificate and a n effective registration certificate

. (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.Page 12

The proposed UAS Air Vehicle s weigh less than 5 5 pounds fully loaded and carr y no passengers, explosive material

, or flammable liquid fuels therefore no display of airworthiness or onboard
documents is required. An equivalent level of safety will be achieved by keeping these documents at the ground control station where the pilot flying the UAS will have access to them to the extent they are applicable. The FAA has issued numerous exemptions to this regulation (s ee E xemptions 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700 )

.

14 C.F.R. §91.405 (a); 407 (a) (1); 409 (a) (1) and (2); 417(a) & (b)

- Maintenance Inspections

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

Petitioner is requesting an exemption to the Maintenance Inspection requirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b)

. These regulations apply only to aircraft with an airworthiness certificate which the UAS in this petition will not
have. Maintenance and inspections will be accomplished by the operator pursuant to the Operating Documents

. An equivalent level of safety is provided because the UAS are limited in size, weight, payload capacity, and will be flown in limited areas for short periods of time. If
mechanical issues arise

, the proposed UAS Air Vehicle s can be land ed immediately and will be operating from no higher than 400 feet AGL.

T he PIC will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and will keep a log of any maintenance performed. A functional test flight will be
conducted and logged following the replacement of a ny flight

- critical components. T he maintenance and inspection proce dures required by Petitioner's O perating D ocuments ensure that an equivalent or higher level of safety will be achieved.

N ationa l Security

This requested exemption does not present a national security issue

. Given that the UAS are small and lightweight, ha ve lost

- link and contingency capabilities

, operate at very low speeds,

ha ve extremely small payload capacities and carr y no flammable, explosive or otherwise
dangerous materials, the operations pose n o threat to national security.

Summary F or Federal Register

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

Petitioner seeks an exemption from the following rules in Title 14 of the Code of Federal Regulations:Page 13

45.23(b); 45.27(a); 61.113; 61.101(e); 91.7(a); 91.9(b)(2); 91.9(c); 91.103; 91.109(a); 91.119(b) and (c); 91.121; 91.151(a); 91.203 (a) & (b); 91.405(a); 91.407(a)(1); 91.409(a)(1) & (2); 91.417 (a) & (b).

The exemption will enhance safety by reducing risk to the general public and property owners from the substantial hazards associated with using conventiona l fixed

- wing aircraft or,

rotorc raft for aerial video, photography, inspection, and training

.

Conclusion

ISKYDRIVE ’s Petition for Exemption satisfies the criteria required in Section 333 of the Reform Act of 2012, including weight, speed, operating capabilities, proximity to airports and populated areas, operation within VLOS

, and national security. The proposed operations in this Petition are similar to those in previousl y issued grants of exemptions, and will benefit the public by improving safety and minimizing risk by reducing the public's exposure to the danger and emissions associated with using manned aircraft to perform similar operations

. The requested

UAS are battery po wered and create no emissions. Additionally , in the unlikely event of an
accident , there would be no fuel to ignite or explode

– thereby presenting significantly less danger to the pilot and other individuals on the ground than one involving a f ull size aircraft.

In consideration of the foregoing, this Petition for Exemption provides the FAA with the necessary justification for granting the requested e xemptions to allow ISKYDRIVE to use the requested UAS to conduct aerial video, photography, ins pection, and training

. Thank you in
advance for your prompt consideration of this exemption request

. Please contact the undersigned should you have any questions, or if additional information is needed

.

Sincerely,

Anthony J. Pucciarella
Alaris Agent for ISkyDrive

CC: Ronney B. Miller