2517 Sayles PlaceS.E. Unit 11 Washington, D.C. 20020 (888) 618-9124
Website: craftandtheoryllc

.com Email: info@craftandtheoryllc

.com

U.S. Department ofTransportation Docket Management System 1200NewJersey Avenue, SE Washington, DC 20590 October 26, 2015

Re: Exemption Request Under Section 333 ofthe FAA Modernization and Reform Act of 2012 and 14 C.P.R. Part 11
Attn: To whom it may concern
Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 C.F.R. Part 11, Craft and Theory, LLC, ("C&T") an operator ofUnmanned Aircraft Systems ("UAS") hereby applies for an exemption from the listed Federal Aviation Regulations ("F ARs") to allow commercial operation ofits UAS. C&T is eligible for a summary exemption for aerial data collection. Specifically, C&T's UAS would be operated for the purpose ofconducting aerial acquisitions and research, videography, gathering ofagricultural data, natural resources, conservation, construction, infrastructure management and inspections, monitoring assessments, search and rescue operations, and reconnaissance in support ofdisaster oremergency situations.

• Types ofaircraft to be flown: o DJI Phantom 2 and 3 series o DJI Inspire 1 o DJI Spreading Wings Series: S800, S900, S1000 o DJI Matrice 100 o Yuneec Q500 o 3DRIRIS+ o 3DR Solo o ParrotBebop o senseFly eXom
The UAS listed above canprovide the PIC withaltitude, speed, battery life, and direction, among other flight parameters. The flight controllers ofthe aircraft listed above utilize GPS to limit the altitude above the ground and limit the radius ofthe distance it flies from the PIC. The flight controllers have failsafe functions (GPS, battery, RC controller) allowing the aircraft to return to the launch site automatically.Introduction and Public Interests
C&T is a full service engineering company specialized in customer-centric solutions. C&T's current thrust is in the development and testing oftechnologies relatedtothe automation ofUAS flight, with a particular focus on onboard and off-board systems to enhance the UAS safety offlight. As such, C&T needs to operate in a variety of operational scenarios in orderto validate the applicability ofits systems on a large scale. C&Tis well versed in the maintenance and operation ofboth off-the-shelfand custom designed UAS.
C&T was a registeredparticipant ofthe UAS Airspace Operations Challenge (one ofthe NASA Centennial Challenges). A purpose-built quadcopterplatform was designed and tested in restricted airspace, and matched procedures for qualification required by an airworthiness audit conducted by AFRL and compliant with the airworthiness criteria for AirForce Group 1 and 2 (below 55lbs GTOW) UAS.
C&Tremains in contact with the UAS COE and the FANDoD/NASA/DHS UAS Science and Research Panel (SARP) andplays a role ininformingthose entities about the technologies and capabilities available for safe operation ofUAS inthe NAS. Itis inthe public's interestto have these FAA standard advising entities informed about the latest technological developments and tests performed onUAS. The SARP is specifically in need ofUAS flight data in representative use cases as to establish encounter models for UAS operating in the NAS. C&T, through its own operations, is in a position to provide such data to the SARP.
C&T is also advancing technology initiatives related to near-obstacle detection sensors and automatic obstacle avoidance algorithms which would greatly enhance the UAS safety offlight during low altitude and landing phases. Near-obstacle detection sensors must inherently be flown close to the ground and other obstacles, therefore these flight tests would be extremely risky and cumbersome ifperformed by a manned aircraft.
Manned aircraft aerial data acquisition creates a greater riskbecause the aircraft are much larger, have combustible fuel, andcarry an onboardhumanpilot. Incontrast, UAS weighing 55 pounds or less andpowered by batteries eliminates virtually all ofthat risk given the reduced mass and lack ofcombustible fuel carried onboard. The UAS carry no passengers orcrew and, therefore, do not expose them to the risks associated with manned aircraft flights. Use ofUASreduces safety concerns when gathering datafrom inaccessible or unstable/unsafe areas. Operation ofUAS will substantially reducethe risk to life and property in the air, and onthe ground, which is commonly associated with traditional manned aircraft flight operations oruse ofelevated work platforms (aka bucket lift, cherry-picker).
The proposed exemption, ifgranted, would allow C&T to safely, efficiently, and economically conduct commercial operations ofUAS meeting or exceeding all ofthe operational and safety requirements Congress has set forth in Section 333. Statutory Authority Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems",provides a mechanism for seeking expedited FAA authorization ofsafe civil UAS operations inthe NAS. Section 333(a) states that the FAA "shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace system before completion ofthe (comprehensive) plan and rulemaking required by section 332(b)(1) of this Actorthe guidance required by section 334 ofthis Act." In Section 332(b)(1), Congress made itclear that Section 333 provides a mechanism for "expedited operation authorization" ifseveral factors are met. Petitioner meets all requirements to permit FAA approval ofcommercial UAS operations.
As described more fully below, the requested exemption wouldpermit the operation of small and relatively inexpensive UAS under controlled conditions in airspace that is: (1) limited; (2) predetermined; (3) controlled as to access, and; (4) would provide an equivalent or increased level ofsafety beyond that existing when manned aircraft are used to accomplish the same purpose. Approval ofthis exemption wouldthereby enhance**saf~ty** and fulfill the Secretary ofTransportation's responsibilities to"

...establish requirements for the safe operation ofsuch aircraft systems in the national airspace system."
Giventhe clear direction in Section 333 ofthe Reform Act, the authority contained inthe Federal Aviation Act, as amended; the strong equivalent level ofsafety surroundingthe proposed operations, and the significant public benefit, including enhanced safety, reduction inenvironmental impacts, including reduced emissions and noise levels associated with allowing UAS operations, the grant ofthe requested exemptions is in the public interest. Accordingly, the applicant respectfully requests that the FAA grant the requested exemption without delay.


### 14 CFR 11.81 (a)- Name and address ofthe Petitioner
Craft and Theory, LLC 2517 Sayles Place S.E. Unit 11 Washington, D.C

. 20020 (888) 618-9124 info@craftandtheoryllc.com


### 14 CFR 11.81 (b)- Exemptions Requested C&T is requesting an exemption from certainparts of 14 CFRcited below in addition to such further exemptions and reliefas the FAA may determine is necessary to permit the operations described herein. §21 , Subpart H §61.23(a) and (c) §61.101(e)(4) and (5) §61.113(a) §61.315(a) §91.7(a) §91.119(c)§91.121 §91.151(a)(1) §91.405(a) §91.407(a)(1) §91.409(a)(l) and (2) §91.417(a) and (b)
14 CFR 11.81 (c)- The extent ofreliefsought, and the reason the reliefis sought §21, Subpart H: Airworthiness Certification The size, weight and enclosed operational area ofthe proposed UAS meet (and exceed) an equivalent level ofsafetypursuantto Section 333 ofthe Reform Act. Therefore, no airworthiness certificate is required in accordance with 14 C.F.R. Part 21, Subpart H. §61.23(a_) 

### and(c): Medical Certificates Exemption# 11221, # 11284, and many others have provided that a U.S. driver's license could beused in lieu ofthe medical certificate. 

### § 61.101(e)(4) & (5): Recreational Pilot Privileges and Limitations & 

### § 61.315(a): Sport Pilot Limitations Exemption# 11221 , # 11284, and many others have declared that there is an equivalent level ofsafety as the FARs by requiring the PIC to "hold either an airline transport, commercial, private, recreational, or sport pilot certificate." Likewise, C&T is also performing commercial UAS work and is asking for the same restrictions whichhave beenpreviously deemed to provide an equivalent level ofsafety. 

### § 61.113 (a): Private Pilot Privileges and Limitations: Pilot in Command Because the UAS will not carry a pilot orpassengers, the proposed operations can achieve the equivalent level ofsafety ofcurrent operations by requiring the PIC operating the aircraft to have a private pilot's license rather than a commercial pilot's license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the UAS is remotely controlled with no livingthing onboard. 

### § 91.7(a): Civil Aircraft Airworthiness As no such certificate will be applicable inthe form contemplated by the FARs, this Regulation is inapplicable. Giventhe size ofthe UAS and the previous exemptions issued for similarUAS, an equivalent level ofsafety will be achieved by ensuring compliance with the UAS operating procedures, manuals, and safety checklists priorto eachflight. 

### § 91.119: Minimum Safe Altitudes Because ofthe lack offlammable fuel, anyrisk associated with these operations is far less thanthose presently presented with conventional aircraft operating at orbelow 500 AGL. In addition, the low-altitude operations ofthe UAS will ensure separationbetween these small UAS operations and the operations ofconventional aircraft that must comply with Section 91.119.§91.121: Altimeter Settings This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set "

... to the elevation ofthe departure airport or an appropriate altimeter setting available before departure." As the UAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level ofsafety will be achieved by the operator, pursuant to the operating manuals. 

### § 91.151(a): Fuel Requirements for Flight in VFR Conditions The UAS will not begin a flight unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed, to fly after that for at least 2 minutes. 

### § 91.405 (a);§ 91.407 (a) (1); § 91.409 (a) (1) & (2); § 91.417(a) & (b): MaintenanceInspections An exemption from these maintenance requirements is warranted because the UA will not have an airworthiness certificate, and the FAA has not developed equivalent part 91 maintenance requirements for UAS. More specifically, no individuals are authorized by the FAA to approve a UAS for return to service under 91.407(a) or to conduct initial airworthiness inspections.
Conclusion
C&T seeks an exemption pursuant to 14 C.F.R. and Section 333 ofthe FAA Modernization and Reform Act of2012, which will permit safe operation ofits UAS commercially, without an airworthiness Certificate. Due to its size, weight, speed, limited operating area, and lack ofcargo, fuel or combustible materials in general, C&T's UAS present no major risk to individuals, nor poses any threat to National Security, and alleviates the need for manned aircraft. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate ofthe FAA Modernization and Reform Act of2012, while also advancing the interests ofthe public, by allowing C&T to safely, efficiently, and economically operate its UAS commercially within the NAS. Sincerely,

Florent Martel Manager