Precision Resource Management Imagery , LLC

Marc B. Allred Stafford, VA 22556 (540) 300

- 6881

marc @ prmimagery. com

Date: April 21 , 201 5

Department of Transportation Docket Management System 1200 New Jersey Ave., SE Washington, DC 20590

RE: Petition of Precision Resource Management Imager y , LLC for Exemption Pursuant to

Section 333 of the FAA Reform Act

Attn: To whom it may concern

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Precision Resource Management Imager y , LLC, operator of Small

Unmanned Aircraft Systems ( “ sUASs ” ) equipped to conduct aerial photography and videography, her eby applies for an exemption from the listed Federal Aviation Regulations ( “ FARs ” ) to allow commercial operation of its sUASs, so long as such operations are conducted

within and under the conditions outlined herein or as may be established by the FAA as r equired by Section 333.

As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under controlled conditions in airspace that is 1) limited 2) predetermined and 3) controlled. The proposed exemption, if granted, would allow Precision Resource Management Imager y , LLC to conduct commercial operations of small

unmanned aircraft systems ( “ UAS ” ) meeting or exceeding all of the operational and safety requirements Congress has set forth in Section 333

.

Precision Resource Management Imager y, LLC is an aerial imagery company owned and run by

Marc B. Allred . Mr. Allred has a Department of Defense Certificate in Intelligence, Surveillance, Reconnaissance, and Collection Management . He has been conducting analysis on behalf of the Department of Defense for over 7 years

. Precision Resource Management Imager y , LLC plans to exploit the capabilities of Unmanned Aerial Systems to offer a multitude of services, including:

- Aerial surveying

- Event Videography

/ Photography

- Agriculture imagery

- Real Estate Videography / Photography

- Aerial filmmaking and photography

- Construction site inspections and monitoringStatutory Authority Section 333, titled “ Special Rules for Certain Unmanned Aircraft Systems ”

,

provides a mechanism for seeking expedited FAA authorization of safe civil UAS operations in the NAS. Section 333( a) states that the FAA “ shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the (comprehensive) plan and rulemaking required by section 332(b)(1) of this Act or the guidance required by section 334 of this Act. ” In Section 332(b)(1), Congress made it clear that Section 333 provides a mechanism for “ expedited operation authorization ” if several factors are met. Petitioner meets all requirements to permit FAA approval of commercial UAS o perations.

The Petitioner requests r elief from the f ollowing: Regulations from which the exemption is requested:

14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2)

14 C.F.R. 91.109

14 C.F.R. 91.119

1 4 C.F.R. 91.121Page 3 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b)

14 C.F.R. 91.215 14 C.F.R. (91.401

- 91.417)

Unmanned Aircraft System sUASs are oftentimes seen as superior to helicopters due to the smaller devices cheaper equipmen t and personnel cost, reduced noise and as such, a much smaller environmental impact which promotes public safety.

We are petitioning for exemption to enable Precision Resource Management Imagery , LLC to

operate a n Iris+ equipped with a two

- axis camera gimbal and using a High

- Def camera. This

sUAS has a built

- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator. The Iris+ also has the failsafe func tion of the autopilot system which means when the communication between the Main Controller and the transmitter

is disconnected the outputs of all command sticks from controller will go to the center position. If the GPS signal is good enough, the system will automatically trigger Return to Home and will land safely.

Please refer to the included Iris+ Instruction Manual for the performance limitations and flight operations.

Aircraft weight is 24oz. with battery. The 2 Axis Camera Gimbal and Camera we igh 8oz.

Gross weight will be 36oz.A p re

- flight inspection will be performed by the PIC in accordance with the factory instruction

manual. An added step will be the inspection of the propellers. A propeller will be replaced if it has any nicks and cracks with a manufacturers authorized propeller.

The sUAS will be maintained in accordance with the manufacturer’s instruction manual and only manufacturer's authorized replacement parts will be used.

FCC Information

The transmitter used for controlling the sUAS complies with part 15 of the FCC rules. Operation is subject to the following two conditions: (1) This device may not cause harmful interference, and (2) this device must accept any I nterference recei ved, including interference that may cause undesired operation. The radio transmitter used for controlling the sUAS is wireless technology

which has been tested and found to be compliant with the applicable regulations governing a

radio transmitte r in the 2.400GHz to 2.4835GHz frequency range.

Antenna Separation Distance When operating our transmitter, the PIC will maintain a separation distance of at least 5 cm between his body (excluding fingers, hands, wrists, ankles and feet) and the antenna to

meet RF exposure safety requirements as determined by FCC regulations.

Pilot in Command and Observer Qualifications and Duties In addition to these flight restrictions, Precision Resource Management Imagery, LLC will

f urther ensure safe operation by requiring that any PIC be thoroughly versed not only in ai rspace and communication issues pertaining to all aircraft operators but also in the unique aspects of UAS flight. As set forth in t he Operations Manual, 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 t o participate in commercial flights on behalf of Precision Resource Management Imag ery , LLC . Petitioner believes that this system will provide a higher level of competency and proficiency for its pilots.

The PIC is responsible for the safe and efficient operation of the aircraft. Specific duties include all preflight preparation, in flight operation, post flight requirements, all procedures including but

not limited to:

 Safe in flight operations

 Ri sk Mitigation to Persons and property

 Airfield Suitability

The Observer must have the visual acuity to observe the sUAS and be able to communicate clearly with the PIC. The Observers duties are;

 W arning the PIC of any impending obstacles in the flight path of the sUAS.

 W arning the PIC of any deviations in the planned flight path of the sUAS.

 W arning the PIC should any unauthorized personnel appear in the area of the planned flight.The Observer will have the authority to order the PIC to terminate the fligh t should he feel the

flight cannot be conducted safely.

General Operating Standards

• Precision Resource Management Imagery , LLC will only operate its sUAS in line of sight of a pilot and/or observer and will operate at sites that are a 'sufficient distance' from populated areas.

Such operations will insure that the sUAS will "not create a hazard to users of the national airspace system or the public."

• Before an operation of a sUAS within 5N M of an airport with a control tower, the control tower will be called to gain permission to operate the sUAS. The PIC will give the position, altitude

and the times the sUAS will be operated. The sUAS will not be operated at an altitude of over 400 feet A GL. Weather minimums will be 3 miles visibility and a 1000 foot ceiling. Before an operation of a sUAS within 5NM of a non

- tower controlled, airport operators will be notified and the PIC will give the right of way to avoid flying in the proximity of full

- scale

aircraft. At no time will the sUAS be operated within the final approach course and the takeoff course of any runway.

• Maximum flight time for each operational flight will be 15 minutes.

• Flights will be terminated at 25% battery power reserve should that occur prior to the 15 minute

limit.

• The sUA S will be programmed so that it will not be operated at an altitude of no more than

400 feet AGL and not more than 200 feet above an elevated platform from which filming is planned.

• Minimum crew for each operation will consist of the sUAS Pilot, and Visual Observer.

• The sUAS operated by the petitioner weighs less tha n 55 pounds, including the payload (i.e. camera, lens, and gimbals).

• The sUAS will operate at speeds of no more than 25 knots, can hover, and can simultaneously move vertically and horizontally.

• Given the small size of the sUAS and the restricted steri le environment within which they will

operate, our sUAS operations adhere to the Reform Act's safety requirements.

The UAS, powered by batteries, is smaller, lighter and more maneuverable than larger aircraft running on combustible fu el, it operates at lower altitudes with no people on board and will thereby reduce current risk levels and thereby enhance safety and diminish the likelihood of death or serious bodily injury. With a small payload and maximum flight time of only 15

minutes , this is offers little or no risk to national security.Low level oblique photos and video from several angles are far more effective than ground based

imagery for displaying the characteristics of large, complex properties with several buildings and larg e trees. The applicants in the past have chartered 2

- seat full

- sized helicopters for this purpose, which has proven more costly than many potential clients have been able to afford. The benefits of reduced cost and improved quality of presentation from the UA will be valuable to and benefit many buyers and sellers of real property.

Additionally, we request that we be allowed to use our system to benefit first responders nearby who might require assistance, including fire fighters, the police, the sheriff, e t al., while remaining subject to all limitations cited in this application as we do so.

(a) No flight will be made with a Gross weight exceeding 55 pounds;

(b) All operations must occur in FAA Class G airspace at no more than 400 ft AGL, at an airspeed of no more than 25 knots and no further than 3/4 NM from the PIC;

(c) All operations must utilize a visual observer (VO). The VO and PIC must be able to communicate by voice at all times during a flight operation;

(d) Operations will be restricted to flights over private property with the permission of the

property owner;

(e) All required permits will be obtained from state and local government prior to operation;

(f ) Precision Resource Management Imagery , LLC will not be operated over densely populated

areas;

(g) Precision Resource Management Imagery , LLC will not be operating over any open

- air assembly of people;

(h) Precision Resource Management Imagery , LLC will not be operating over heavily trafficked roads;

(i) Precision Resource Management Imagery , LLC will not be operating at night.

EXEMPTION REQUESTS A ND EQUIVALENT LEVEL OF SAFETY

Precision Resource Management Imagery , LLC requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of

the sUAS System:

14 CFR Part 21, Airworthiness Certificates This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental cer tificate be issued for the Iris+ under either or both of the following provisions:21.191 Experimental certificates. Experimental certificates are issued for the following purposes:

(a) Research and development

. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. (b) Showing compliance with regulations

. Conducting flight tests and other operations to show compliance with the airworthiness regulations in cluding flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since the experiment al certificate can be used for commercial purposes such as market surveys, sales demonstrations, and customer crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry persons o r property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UA's light weight, being constructed primarily of carbon fiber and plastic, we propose that the UA will be at least as safe, if not safer, than a co nventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for airworthiness certif icate in general, citing the equivalent level of safety outlined in the previous paragraph.

14 CFR 45.23 Display of marks; general and 45.29 Size of marks. These regulations provide that each aircraft must display "N" and the aircraft's registration

number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. The sUAS does not have an entrance in which the word "EXPERIMEN TAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" in the placard on the top of the aircraft, as shown above, where the PIC (Pilot In Control), VO (Visual Observer) and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the permanent pla card discussed in the previous paragraph will provide the aircraft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words

"Unmanned Aircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will operate within 3/4 NM of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin.

14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 61.133 Commercial pilot privileges and limitations. Precision Resource Management Imagery, LLC seeks exemption from 14 CFR § 61.113, which restricts private pilot certificate holders from flying aircraft for compensation or hire, and would also require a second class medical certificate. The purpose of Part 61 is to ensure that the skill and competency of any PIC matches the airspace in which the PIC will be operating, as well as requiring certifications if the private pilot is carrying passengers or cargo for hire. I n this case,

while the UASs will be operated as part of a commercial operation, it carries neither passengers

nor cargo. In the Grant of Exemption in FAA Docket No. FAA

- 2014

- 0352, the FAA determined

that the unique characteristics of UAS operation outside of controlled airspace did not warrant

the addition cost and restric tions attendant with requiring the PIC to have a commercial pilot

certificate and class II medical certificate.The restrictions Precision Resource Management Imagery has placed on its UAS operations meet

or exc eed the restrictions similarly imposed on Astraeus Aerial in FAA Docket No. FAA

- 2014

- 0352. Precision Resource Management Imagery, LLC will operate away from persons and property not involved in the operation, and flights will be conducted using VLOS at 400' AGL or

below. A NOTAM will b e issued between 48 and 72 hours before the flight is to occur, and the flight will be coordinated with the applicable FSDO.

14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness certificate

. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation

is inapplicable.

14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements

. This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this req uirement is to ensure that flight manual information is available to the aircrew while operating the aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation, but

the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the intent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground station anyti me the aircraft is in, or preparing for, flight.

14 CFR 91.109 Flight Instruction; 14 C.F.R. § 91.109(a) states "[n]o person may operate a civil a ircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual

controls." UASs and remotely piloted aircraft, by their design, do not have functional dual

controls. Instead, flight control i s accomplished through the use of a device that communicates

with the aircraft via radio communications. Accordingly, an exemption will be required for the flight instruction requirements of 14 C.F.R. § 91.109(a). Given the size and speed of the UAS

that Precision Resource Management Imagery, LLC intends to use, an equivalent level of safe training can still be performed without dual controls because no pilot or passengers are aboard

the UAS and all persons will be a safe distance away in the event that the UAS experiences any difficulties during flight instruction. Moreover , all flight training will be conducted in controlled and sterile environment. As a whole, Precision Resource Management Imagery, LLC s afety procedures ensure that the proposed UAS operations provide an equivalent or higher level of safety than that provided by the flight instruction regulations.

91.119 Minimum safe altitu des : The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, vessel, vehicle, or structure. Since the one of the mission s of the sUAS would be photography or survey of persons, vesse ls, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over property or persons where permission has been obtained and careful pre

- planned flight path has been performed. The airc raft will be operated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and struc tures is minimal compared to manned aircraft, which should be considered in granting the exemption.CFR 91.121 Altimeter settings

.

The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 400 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via r adio

from the sUAS on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout.

14 CFR 91.151 Fuel requirements for flight in VFR conditions

. The regulation provides that no person may begin a flight in an airplane under day

- vFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragra ph is to provide an energy reserve as a safety buffer for delays to landing. The sUAS is battery operated and the maximum duration of flight from a single battery charge is 12 minutes with a 20% reserve. Since the aircraft will never fly more than 3/4 NM f rom the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy

. "

14 CFR 91.203(a) & (b) Civil aircraft: Certifications required

. The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Additionally, subparagrap h (b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." T he sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for this aircraft by the FAA will be with the crew at the ground control station and ava ilable for inspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the wor d "EXPERIMENTAL" to satisfy the requirement of 14 CFR 45.23.

14 CFR Subpart E (91.401

- 91.417)

- Maintenance, Preventative Maintenance, Alterations The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy condition, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform ma intenance and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that the aircraft is in an airworthy condition prior to every flight and in addition conduct detailed inspections after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on

- board computer. All ot her maintenance will be performed by the manufacturer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equ ivalent level of safety.Safety and Benefits of the UAS

Precision Resource Management Imagery , LLC will be using the UAS in a variety of applications that generally require expensive full

- size manned aircraft to complete. Small, light,

unmanned aerial vehicles offer a my riad benefits over the use of full

- sized manned aircraft for electric power line inspection

, oil/gas pipeline inspection, advanced agriculture, film and still photography, just to name a few. Replacing significantly larger manned aircraft carrying crew

and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin of safety for the pilots and crew. By granting Precision Resource Management Imager y
, LLC ‘ s requested exemptions, the FAA will help drive development of safe and successful

comm ercial UAS operations and will advance the public knowledge base for such operations. Precision Resource Management Imagery , LLC is committed to promoting the UAS research efforts of policymakers including the FAA, NASA, DOD and DARPA by sharing data from its

commercia l UAS operations and serving as a resource for future UAS research operations. Thus, the FAA has good cause to grant this Petition.

Conclusion As pointed out in this application, all the SUAs which our company would use, under authorization by the US DOT

- F AA, are small, light

- weight devices operated within the line of sight of the Pilot

- in

- Command (PIC), less than 400 feet above the ground and outside 5 miles from any airport, heliport, seaplane base, spaceport, or other location with aviation activities,

u nless the air traffic control authorities (ATC) have been notified and have authorized each flight

within a radius of this distance.

All our SUAs have proven capability for controlled flight. They are devices offered for general

sale on the market around the world and have often been used as Model Aircraft in the USA. We are certain that the studies conducted until now by the FAA, about Section 332, Public Law

112

- 95, 2014, have already provided you with the assurances on the airw orthiness of SUAs such

as ours.

For the foregoing reasons, the exemptions requested herein should be granted and Precision Resource Management Imagery, LLC should be permitted to conduct small UAS operations in

accordance with its manuals and all other operating paramet ers deemed necessary and appropriate by the FAA. The submission of this application and its contents is the best

demonstration that indeed it is possible to pursue the authorization process so that some SUAs may be used for legitimate commercial activities and under reasonably safe conditions.

Signed

Marc B. Allred

Owner of Precision Resource Management Imagery, LLC