### August 10, 2015

Exemption No. 12402 Regulatory Docket No. FAA

–20 15

– 15 36

Mr. Stephen C. Gowdy Gowdy Brothers Aerospace 1540 Yorkshire Lane Shakopee, MN 55379
Dear Mr. Gowdy: This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends. By letter dated April 30, 2015 , you petitioned the Federal Aviation Administration (FAA) on behalf of Gowdy Brothers Aerospace (hereinafter petitioner or operator) for an exemption

. The petitioner requested to operate an unmanned aircraft system (UAS) to conduct aerial videography, photography, and inspections
. See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption

. The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner

. Airworthiness Certification
The UAS proposed by the petitioner is a Carbon Core Octocopter and HH Blade 350QX3

. In accordance with the statutory criteria provided in Section 333 of Public Law 112

−95 in reference to 49 U

. S

.C

. § 44704, and in consideration of the size, weight, speed, and limited operating area associated with the aircraft and its operation, the Secretary of Transportation has determined that this aircraft meets the conditions of Section 333. Therefore, the FAA

### 2

finds that relief from 14 CFR part 21 , Certification procedures for products and parts, Subpart H

— Airworthiness Certificates, and any associated noise certification and testing requirements of part 36, is not necessary. The Basis for Our Decision You have requested to use a UAS for aerial data collection 1



### . The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in your petition. In Grants of Exemption Nos
. 11062 to Astraeus Aerial (see Docket No. FAA−2014−0352), 11109 to Clayco, Inc. (see Docket No. FAA

−2014

−0507), 11112 to VDOS Global, LLC (see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. (see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest. Having reviewed your reasons for requesting an exemption, I find that

—

 They are similar in all material respects to relief previously requested in Grant of Exemption Nos. 11 062, 11109, 11112, and 11213 ;
 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation you present; and

 A grant of exemption is in the public interest.
Our Decision In consideration of the foregoing, I find that a grant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, delegated to me by the Administrator, Gowdy Brothers Aerospace is granted an exemption from 14 CFR §§ 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)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection

. This exemption is subject to the conditions and limitations listed below.
Conditions and Limitations
In this grant of exemption, Gowdy Brothers Aerospace is hereafter referred to as the operator.

1 Aerial data collection includes any remote sensing and measuring by an instrument(s) aboard the UA. Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the UA.

### 3

Failure to comply with any of the conditions and limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.
1. Operations authorized by this grant of exemption are limited to the Carbon Core Octocopter and HH Blade 350QX3 when weighing less than 55 pounds including payload. Proposed operations of any other 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. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.
4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.
5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

-issued airman medical certificate or U.S. driver’s license.
6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement 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.
7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible 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. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised

### 4

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 that 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. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding updates or revisions to the operating documents.
8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. , replacement of a flight critical component, must undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.
9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.
10. Prior to each flight, the PIC must conduct a pre

-flight inspection and determine the UAS is in a condition for safe flight. The pre

-flight inspection must account for all potential discrepancies, e.g. , inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.
11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.
12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.
13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pilot certificate. The PIC must also hold a current 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 must 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.
14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under 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

### 5

14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.
15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.
16. 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

-published 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.
17. 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 from the PIC.
18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre
-determined location within the private or controlled

-access property. 19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies.
20. 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 power recommended by the manufacturer if greater.
21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations shall be conducted in accordance with an ATO

-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA

. 22. All aircraft operated in accordance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.

### 6

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon request.
24. The UA must remain clear and give way to all manned aviation operations and activities at all times.
25. The UAS may not be operated by the PIC from any moving device or vehicle.
26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons ; and b. The owner/controller of any vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard

. The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.
27. All operations shall be conducted over private or controlled

-access property with permission from the property owner/controller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.
28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS−80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

. If this exemption permits operations for the purpose of closed

-set motion picture and television filming and production, the following additional conditions and limitations apply.
29. The operator must have a motion picture and television operations manual (MPTOM) as documented in this grant of exemption.

### 7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction over the area of proposed filming. The 3

-day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following: a. Dates and times for all flights; b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on

-scene operation of the UAS; d. Make, model, and serial or N−Number of UAS to be used; e. Name and certificate number of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.
31. Flight operations may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM. Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91. This exemption terminates on August 31, 2017 , unless sooner superseded or rescinded. Sincerely, /s/ John S. Duncan Director, Flight Standards Service

EnclosuresGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 1 UNITED	STATES	OF	AMERICA DEPARTMENT	OF	TRANSPORTATION FEDERAL	AVIATION	ADMINISTRATION

WASHINGTON,	DC
**IN	THE	MATTER	OF	THE	PETITION	FOR	EXEMPTION	OF:** 

# GOWDY	BROTHERS	AERSPACE

**FOR	AN	EXEMPTION	SEEKING	RELIEF	FROM THE	REQUIREMENTS	OF	TITLE	14	OF**  **THE	C ODE	OF	FEDERAL	REGULATIONS**  **SECTIONS	61.113(a)	&	(b),	91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1), 91.409(a)(1)	&**  **(a)(2),	AND	91.417(a)	&	(b)	CONCERNING COMMERCIAL	OPERATION	OF	CARBON	CORE	OCTOCOPTER/HH	BLADE	350**  **QX3 AP**  **UNMANNED AIRCRAFT	SYSTEMS**  **PURSUANT	TO	SECTION	333	OFTHE	FAA	MODERNIZATION AND	REFORM	ACT	OF	2012	(PUBLIC	LAW	112** 
**- 95)** 

Submitted	on	April	30,	2015 Gowdy	Brothers	Aerospace 1540	Yorkshire	Lane, Shakopee,	MN	55379 763

-496

- 9551 Steve@GowdyBrothers.comGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 2

**TABLE	OF	CONTENTS** Page

GLOSSARY	OF	ABBREVIATIONS

................................ ................................ ................................ ................................ . 3 SUMMARY

................................ ................................ ................................ ................................ ................................ ............. 4 INTRODUCTION	AND	INTERESTS	OF THE	PETITIONER

................................ ................................ ................ 4 BACKGROUND

................................ ................................ ................................ ................................ ................................ ..... 5 BASIS	FOR	PETITION

................................ ................................ ................................ ................................ ....................... 5 Name	and	Address	of	Petitioner

................................ ................................ ................................ ................................ . 7 A.	Name	And	Address	Of	The	Petitioner

................................ ................................ ................................ ................................ . 7 B.	The	Specific	Sections	Of	14	C.F.R.	From	Which	Gowdy	Brothers	Aerospace	seeks	Exemption

................ 7 1.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Section	61.113(a)	And (b).

................................ ................................ ................................ ................................ ................................ ................................ ...... 7 2.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Section	91.7(a).

................ 8 3.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Section	91.121.

................. 8 4.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Section	91.151(b).

.......... 8 5.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Section	91.405	(a).

.......... 9 6.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Section	91.407(a)(1)

..... 9 7.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Sections	91.409(a)(1) And	91.409(a)(2).

................................ ................................ ................................ ................................ ................................ ....... 9 8.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of	Sections	91.417(a)	And 91.417(b).

................................ ................................ ................................ ................................ ................................ ....................... 9 C.	The	Extent	Of	Relief	Gowdy	Brothers	Aerospace	Seeks	And	The	Reason	Gowdy	Brothers Aerospace Seeks	The	Relief.

................................ ................................ ................................ ................................ ................................ ............. 10 D.	The	Reasons	Why	Granting	Gowdy	Brothers	Aerospace	Request	Would	Be	In	The	Interest;	That	Is, How	It	Would	Benefit	The	Public	As	A	Whole.

................................ ................................ ................................ ................ 13 E.	The	Reasons	Why	Granting	The	Exemption	Would	Not	Adversely	Affect	Safety,	Or	How	The Exemption	Would	Provide	A	Level	Of	Safety	At	Least	Equal	To	That	Provided	By	The	Rule	From Which	Gowdy	Brothers	Aerospace	Seeks	Exemption.

................................ ................................ ................................ . 15 F.	A	Summary	That Can	Be	Published	In	The	Federal	Register	stating:	The	Rules	From	Which	Gowdy Brothers	Aerospace	Seeks	Exemption:

................................ ................................ ................................ ............................... 25 G.	Any	Additional	Information,	Views,	Or	Arguments	Available	To	Support	Gowdy	Brothers	Aerospace's Request.

................................ ................................ ................................ ................................ ................................ .............................. 25 CONCLUSION

................................ ................................ ................................ ................................ ................................ ..... 25 APPENDICES:

................................ ................................ ................................ ................................ ................................ ..... 27 A

- CCO	w/Wkm	M	TECHNICAL	SPECIFICATIONS

................................ ................................ ..................... 28 B

- HH	Blade	350QX3	AP	TECHNICAL	SPECIFICATIONS

................................ ................................ ......... 29 C

- DJI	Wkm	M

– Manufacturer's	User	Manual

................................ ................................ .............................. 30 D

- HH	Blade	350QX3	AP	Manufacturer’s	User	Manual

................................ ................................ ............ 31 E

- Gowdy	Brothers	Aerospace	Monthly	Maintenance	and	Repair	Log

................................ ............. 32Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 3 

## GLOSSARY	OF	ABBREVIATIONS

AGL AOI ATC ATO AV CCO CFR COA FAA FAR GCS GPS HH LOL NAS NOTAM PIC Section	333
SO SOP UA UAS VFR VLOS VMC VTOL Wkm	M Above	Ground	Level Area	of Interest Air	Traffic	Control Air	Traffic	Organization Aerial	Vehicle Carbon	Core	Octocopter Code	of	Federal	Regulations Certificate	Of	Authorization Federal	Aviation	Administration Federal	Aviation	Regulation Ground	Control	Station Global	Positioning	System Horizon	Hobby	Blade	350 QX3AP

Loss	Of	Link National	Airspace	System Notice	To	Airman Pilot	In	Command FAA	Modernization	and	Reform Act	of 2012	(FMRA)	Section	333

Safety	Observer Standard	Operating	Procedures

Unmanned	Aircraft Unmanned	Aircraft	System Visual	Flight	Rules Visual	Line	Of	Site Visual	Meteorological	Conditions Vertical	Take

- Off	and	Landing DJI	Flight	Control	SystemGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 4 

## SUMMARY
Gowdy Brothers Aerospace seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a) (2), and 91.417(a) & (b), to operate	an	Unmanned	Aircraft	System	pursuant	to	Section	3 33	of	the	FAA	Modernization	and	Reform Act of 2012 (FMRA). This exemption will permit to operate an Unmanned Aircraft System (UAS) for the commercial purpose of inspecting bridges and conducting aerial video and photography of construction	sites,	real	estate	and	landscape	over	certain	areas	of	the	United	States.



## INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER
Gowdy Brothers Aerospace, LLC is made up of four Gowdy Brothers, additional family, friends and employees, who between them have education and experience as follows: an MBA, two Doctorate degrees in Business Administration and Education, an FAA Certified Private Pilot since 1997 and a past owner of a 1972 Cessna Skyhawk 172, and a FAA Certified Airframe and Powerplant Mechanic, 30+ years experience, Air Force, Air National Guard, Department of Homeland Security and over 50+ years of mentoring and coaching experience. http://www.gowdybrothers.com/experience

-weoffer.html for	additional	experience	and	company	information.

Gowdy Brothers Aerospace has a relationship to assist Clark Engineering, a 75

-year old civil and structural engineering firm, with over 60 engineers in staff and offices in Minnesota and South Dakota. Clark Engineering has an agreement with the State of South Dakota to provide structural engineering inspection reports on	more	than sixty percent of the State of South Dakota’s bridges. At present these inspections are time consuming and require expensive equipment and lifts to be moved from bridge to bridge with re- calibration required at each bridge site. Today, Clark Engineering	is	able	to	complete	an	average of	only	two	bridge	inspections	per	day.		Clark	Engineering estimates using Gowdy Brothers Aerospace UAV’s, the engineering firm could complete at least four bridge inspections per day. Completing twice the amount of inspections during the same amount of time saves the taxpayers of South Dakota and creates less disruption for South Dakota traffic having to	be	re

- routed	for	shorter	periods	of	time.
Gowdy Brothers Aerospace provides our clients with expertise and knowledge in advanced photography and video s olutions to increase efficiency, productivity and effectiveness. Gowdy Brothers	Aerospace	has	many	years	experience in	Photographic	and	Video	Technology.Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 5

The objective of Gowdy Brothers Aerospace's Bridge Inspections, Aerial Video and Photography operations	is	to	provide	high	quality	imaging	for	a	variety	of	commercial,	public,	and	residential	uses, specifically	targeting:

• Structural	engineering	bridge	inspections

• Construction sites

• Appraisals

• Real

- estate	marketing

• Aerial	acquisitions	used	for	inspections	of	public	and	private	structures.

• Search	and	Rescue	operations 

## BACKGROUND

Unmanned	Aircraft	Systems:

 CCO	w/Wkm	M,

 HH	Blade	350 QX3 AP	UAS's
Gowdy	Brothers	Aerospace seeks	an exemption to	operate	DJI	&	HH	Blade	systems for	compensation

or hire within the NAS. The CCO w/Wkm M and HH Blade 350QX3 AP are vertical take offand landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) Utilizing a 2.8Mhz Remote	Control	system.
The	CCO	w/Wkm	M	has	a	maximum	gross	weight	of	approximately	15	pounds	0	ounces,	while	having a	width	of	40 inches	and	a	height	of	19	inches,	and	a	maximum	speed	of	approximately	43	knots.

The HH Blade 350 QX3 AP has a maximum gross weight of 4 pounds 0 ounces, a length of18.3 inches, width of 17.7 inches, height of 7.48 inches, and a maximum speed ofApproximately 29 knots.

The CCO w/Wkm M is equipped with 8 main rotors, and the HH Blade 350 QX3 AP with four main rotors;	utilizing	Lithium	Polymer	batteries	to	power	the	electric	motors.

The CCO w/Wkm M and H H Blade 350 QX3 AP UAS's that will be operated by Gowdy Brothers Aerospace will be registered in accordance with 49 U.S.C. 44103, Registration of	Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration, and marked in accordance with 14 C.F.R. Part 45, Identification	and	Registration	Marking

. 

## BASIS	FOR	PETITION

Petitioner, Gowdy Brothers Aerospace, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), SectionGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 6

333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the CCO w/Wkm M And HH Blade 350 QX3 AP UAS's in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).

In	consideration of	the	speed, weight,	size,	and	limited	operating	area	associated with	the	unmanned aircraft and its operation, Gowdy Brothers Aerospace's operation of CCO w/Wkm M and HH Blade 350 QX3 AP UAS's meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness	certificate	in	accordance	with	14	C.F.R.	Part	21,	Subpart	H.
Accordingly, Gowdy Brothers Aerospace requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b),	as	these	sections	set	forth	requirements for	maintenance that	only	apply	to	aircraft	with	an	airworthiness	certificate.
Gowdy Brothers Aerospace submits that the requested relief is proper since an equivalent level of safety will be ensured. Gowdy Brothers Aerospace will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UAS's using the methods, techniques,	and	practices prescribed	in	the operating documents	(i.e.,	Monthly	Maintenance	Log,	and CCO w/Wkm M and HH Blade 350 QX3 AP Instruction Manual). Furthermore, Gowdy Brothers Aerospace will document and maintain all maintenance records for the CCO w/Wkm M and HH Blade	350 QX3 AP	UAS's.

Relief fro m certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations:	Pilot	in	command , is requested by Gowdy Brothers Aerospace to the extent necessary to allow	a	Pilot	in	Command	(PIC)	holding	a	private	pilot	or	higher	l evel	certificate,	as	well	as	an	airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and current requirements, that the PIC is able to safely operate the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining	appropriate	distances	from	people,	vessels,	vehicles	and	structures.
Gowdy Brothers Aerospace seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, because the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such, Gowdy Brothers Aerospace submits that he will ensure that the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's are in an airworthy condition, prior to every flight, by determining that the UAS's are in compliance with the operating documents (i.e., Monthly Maintenance Log, and CCO w/Wkm M	and HH Blade 350 QX3 AP Instruction Manual), and that the aircraft are in a condition for safe flight. Gowdy Brothers Aerospace also seeks an exemption from the requirements of Section 91.121, entitled AltimeterGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 7

Settings, as the CCO w/ Wkm M and HH Blade 350 QX3 AP UAS's will not have a typical barometric altimeter onboard. However, altitude information of the CCO w/ Wkm M and HH Blade 350 QX3 AP UAS's will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring of the flight path. This altitude information, combined with Gowdy Brothers Aerospace's operation of the CCO W/ Wkm M and HH Blade 350 QX3 AP UAS's within visual line of sight, at or below	400 feet	AGL,	will	ensure	a	level	of	safety	equivalent	to	Section	91.121.

Additionally, Gowdy Brothers Aerospace seeks an exemption from the requirements of Section 91.151(b), entitled Fuel	requirements	for	flight	in	VFR	conditions

. Gowdy Brothers Aerospace submits that safety will not be affected by operation of the CCO w/ Wkm M and HH Blade 350 QX3 AP UAS's during daylight	hours in	visual	meteorological	conditions	(VMC)	under	visual	flight	rules	(VFR), with enough battery power to fly for a total duration of approximately 10 minutes for the intended photo shoot or	inspection and,	assuming normal cruising	speed,	to	fly	after	that	for	at	least	2.5	minutes	for recovery	and	landing.

In accordance with 14 C.F.R. § 11.81, Gowdy Brothers Aerospace provides the following information in	support	of	its	petition	for	exemption:



## Name	and	Address	of	Petitioner

**A. Name	An** **d	Address	Of	The	Petitioner**
The	name	and	address	of	the	Petitioner	and	point	of	contact	is: Gowdy	Brothers	Aerospace Attention:	Steve	Gowdy,	Private	Pilot 1540	Yorkshire	Lane, Shakopee,	MN	55379 763

-496

- 9551 Email: Steve@GowdyBrothers.com


### B.	The	Specific	Sections	Of	14	C.F.R.	From	Which	Gowdy	Brothers	Aerospace **seeks	Exemption 1.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of**  **Section	61.113(a)	And	(b).**Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 8

Section	61.113,	entitled	Private	pilot	privileges	and	limitations: Pilot	in	command ,	subsections	(a)	and (b)	prescribe	the	following,	in	relevant	part: (a)	No	person	who	holds	a	private	pilot	certificate	may	act	as	a	pilot	in	command	(PIC)	of	an aircraft that is carrying passengers or property for compensation or hire; nor may that person,	for	compensation	or	hire,	act	as	PIC	of	an	aircraft. (b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any	business	or	employment	if

— (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers	or	property	for	compensation	or	hire.



### 2.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of **Section	91.7(a).**
Section	91.7,	entitled Civil	aircraft	airworthiness,	subsection	(a),	states	the	following: (a) No	person	may	operate	a	civil	aircraft	unless	it	is	in	an	airworthy	condition.



### 3.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of **Section	91.121.** Section	91.121,	entitled	Altimeter	settings,	subsection	(a),	states the	following,	in	part: (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft,	as	the	case	may	be,	by	reference	to	an	altimeter	that	is	set,	when	operating

-- (1)	Below	18,000	feet	MSL,	to

-- (i) The current reported altimeter setting of a station along the route and within 100 nautical	miles	of	the	aircraft; (ii)	If	there	is no	station	within the	area prescribed in	paragraph	(a)(1)(i)	of this	section,	the current	reported	altimeter	setting	of	an	appropriate	available	station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport	or	an	appropriate	altimeter	setting	available	before	departure.


### 4.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirem**ents	Of Section**  **91.151(b).**

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states the following: (b) 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 intended landing and, assuming	normal	cruising	speed,	to	fly	after	that	for	at	least	20	minutes.Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 9



### 5.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirement**s Of**  **Section 91.405**  **(a).**

Section	91.405,	entitled Maintenance	required ,	subsection	(a),	states	the	following: Each	owner	or	operator	of	an	aircraft

— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired	as	prescrib ed	in	part	43	of	this	chapter.


### 6.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of **Section	91.407(a)(1)**

Section 91.407, entitled Operation after maintenance, preven tive maintenance, rebuilding, or alteration, subsection	(a)(1),	states	the	following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding,	or	alteration	unless

-- (1)	It	has	been	approved	for	return	to service	by	a	person	authorized	under	§	43.7	of	this	chapter.


### 7.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of

**Sections	91.409(a)(1)	And	91.409(a)(2).**

Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar	months,	it	has	had

-- (1)	An	annual	inspection	in	accordance	with	part	43	of	this	chapter	and	has	been	approved	for	return to	service	by	a	person	authorized	by	§	43.7	of	this	chapter	or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.


### 8.	Gowdy	Brothers	Aerospace	Seeks	Exemption	From	The	Requirements	Of

**Section s	91.417(a)	And	91.417(b).** 
Section	91.417,	entitled Maintenance	records,	subsections	(a)	and	(b),	states the	following: (a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner or operator	shall	keep	the	following	records	for	the	periods	specified	in	paragraph	(b)	of	this	section: (1) Records of the maintenance, preventive maintenance, and alteration and records of th e 100

-hour, annual, progressive, and other required or approved inspections, as appropriate,Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 10 for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an	aircraft.	The	records	must	include

-- (i) A description (or reference to data acceptable to the Administrator) of the work performed;	and (ii)	The	date	of	completion	o f	the	work	performed;	and (iii) The signature, and certificate number of the person approving the aircraft for return	to	service. (2)	Records	containing	the	following	information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor. (ii) The current status of life

-limited parts of each airframe, engine, propeller, rotor, and	appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required	to	be	overhauled	on	a	specified	time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances	are	maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or Safety directive number	and	revision	date.	If	the	AD	or	safety	directive	involves	recurring	action,	the time	and	date	when	the	next	action	is	required. (vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines, rotors, propellers, and appliances. (b)	The	owner	or	operator	shall	retain	the	following	records	for	the	periods	prescribed: ( 1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred	with	the	aircraft	at	the	time	the	aircraft	is	sold. (3)	A	list	of	defects	furnished	to	a	registered	owner	or	operator	under	§	43.11	of	this chapter shall be retained until the defects are repaired and the aircraft is approved for	return to	service.



### C.	The	Extent	Of	Relief	Gowdy	Brothers	Aerospace	Seeks	And	The	Reason

**Gowdy	Brothers	Aerospace	Seeks	The	Relief.**Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 11 **1. Extent	Of	Relief	Gowdy	Brothers	Aerospace	Seeks	And	The	Reason	Gowdy	Brothers** 

**Aerospace	Seeks	Relief	From	Section	61.113(a)	And (b).** 
Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in command

, is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

hour	and	currency requirements, to	conduct	the	proposed	UAS	flight operations	for	compensation	or hire.
This	relief	is	requested	since	the	limitations	set	forth	in	Section 61.113(a)	and	(b)	state	that a	private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does	not	carry	passengers	or	property	for	compensation	or	hire.

As set forth more fully below, Gowdy Brothers Aerospace submits that an equivalent level of safety will be maintained because no PIC will be allowed to operate the CCO W/Wkm M or HH Blade 350 QX3 AP UAS's unless that PIC has met certain flight

-hour and And current requirements, demonstrating that the PIC is able to safely operate either the CCO w/Wkm M or HH Blade 350 QX3 AP UAS's in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people,	vessels,	vehicles	and	structures.
Further, Gowdy Brothers Aerospace submits that all flights of the CCO w/Wkm M And HH 350 QX3 AP	UAS's,	conducted by the PIC	pursuant	to	the	grant of this	Petition:	(1)	will be incidental	to	Gowdy Brothers Aerospace's business; and (2) will not carry passengers or property for compensation or hire.
**2.Extent	Of	Relief	Gowdy	Brothers Aerospace	Seeks	And	The	Reason	Gowdy	Brothers**  **Aerospace	Seeks	Relief	From	Section	91.7(a).**
Relief from Section 91.7(a) entitled Civil	aircraft	airworthiness, is requested to the extent required to allow Gowdy Brothers Aerospace to determine that the CCO w/Wkm M and HH Blade350 QX3 AP UAS's are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with the operating documents (i.e., the Monthly Maintenance Log and CCO w/Wkm M and 350 QX3 AP manuals.
Gowdy Brothers Aerospace seeks the requested relief because the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, Gowdy Brothers Aerospace will ensure that the CCO w/Wkm M and HH Blade 3 50 QX3 AP UAS's are in airworthy condition based upon its compliance with the operatingGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 12

documents	(i.e.,	Monthly	Maintenance	Log,	and	CCO w/Wkm	M	and	HH	Blade	350 QX3 AP	Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as	stated	in	the	conditions	and	limitations	below.
**3.	Extent	Of	Relief	Gowdy	Brothers	Aerospace	Seeks	And	The	Reason	Gowdy	Brothers**

**Aerospace	Seeks	Relief	From	Section	91.121.**
Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link to downlink altitude information from the UA to the PI C at the ground control station (GCS). Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), Gowdy Brothers Aerospace seeks the requested relief because the CCO w/Wkm M and HH	Blade	350 QX3 AP	UAS’s	altimeter	may	be	set	on	the	ground	to	zero	feet	AGL,	rather	than	the	local barometric	pressure	or	field	altitude,	before	each	flight. Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight,	and	provides	the	PIC	with	altitude	information	of	the	UA	on	the	heads

-up	display	of	the	GCS. **4.	Extent	Of	Relief	Gowdy	Brothers	Aerospace	Seeks	And	The	Reason	Gowdy	Brothers**

**Aerospace	Seeks	Relief	From	Section	91.151(b ).**  Relief	from	Section	91.151(b)	entitled	Fuel	requirements	for	flight	in	VFR conditions,	is	requested	to the	extent	required	to	allow	flights	of	the	battery	powered	CCO CO	w/Wkm	M	and	HH	Blade	350 QX3 AP UAS's during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR),	for	a	total	duration	of	10	minutes	to the	first point	of	intended	landing	and,	assuming normal cruising speed, to fly after that for at least 2.5 minutes. Gowdy Brothers Aerospace seeks the requested	relief because	without	an	exemption	from	Section	91.151(b),	the	flight	time	duration	of	the battery powered CCO W/Wkm M and HH Blade 350 QX3 AP UAS's will severely constrain the practicality of any aerial video or still photo flight operations that Gowdy Brothers Aerospace proposes	to	conduct	pursuant	to	this	Petition.
Significantly, as set forth below, the technical specifications of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's, the CCO w/Wkm M and HH Blade 350 QX3 AP operating documents and Gowdy Brothers Aerospace's proposed operating limitations, ensure that Gowdy Brothers Aerospace will safely operate the battery powered CCO w/Wkm M and HH Blade 350 QX3 AP UAS's during daylight hours	in	visual	meteorological	conditions	(VMC),	under	visual	flight	rules	(VFR),	with	enough	batteryGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 13

power to fly for a total duration of 10 minutes to the firstpoint of intended landing and, assuming normal	cruising	speed,	to	fly	after	that	for	at	least2.5	minutes.
**5.Extent	Of	Relief	Gowdy	Brothers	Aerospace	Seeks	And	The	Reason	Gowdy	Brothers**

**Aerospace	Seeks	Relief	From	Sections	91.405(a), 91.407(a)(1),** 

**91.409(a)(1)	&	(a)(2),	And	91.417(a)	&	(b).**
Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, Gowdy Brothers Aerospace requests relief from these Sections because the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's do not require airworthiness certificates. As set forth more fully below, the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, Gowdy Brothers Aerospace will use trained technicians to perform maintenance, alterations, or preventive	maintenance	on	the	UAS's using	the	methods,	techniques,	and	practices	prescribed	in	the UAS operating documents (i.e., the Aerial Operations Manual, Monthly Maintenance Log, and CCO w/Wkm M and HH Blade 350 QX3 AP Instruction Manual). Furthermore, Gowdy Brothers Aerospace will documentand maintain all maintenance records for the CCO w/Wkm M and HH Blade 350 QX3 AP	UAS's.


### D.	The **Reasons	Why	Granting	Gowdy	Brothers	Aerospace	Request	Would	Be In	The	Interest;	That	Is,	How	It	Would	Benefit	The	Public	As	A	Whole.**  Granting the present Petition will further the public interest by allowing Gowdy Brothers Aerospace to safely, efficiently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States. Additionally, use of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's will decrease congestion of the NAS, reduce pollution, and provide significant benefits to the the economy. Notably, the benefits of Gowdy Brothers Aerospace's proposed operation of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's will be realized	without	implicating	any	privacy	issues.

**1.The	Public	Will	Benefit	From	Decreased	Congestion	Of	The	NAS.**
The CCO w/Wkm M and HH Blade 350 QX3 AP UAS's are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned aircraft needed to perform aerial acquisitions, an exemption	allowing	the	use	of	the	CCO	w/Wkm	M	and	HH	Blade	350 QX3 AP	UAS's	would	reduce	the amount	of	manned	aircraft	in	the	NAS,	reduce	noise	and	air	pollution,	as	well	as	increase	the	safety	of life	and	property	in	the	air	and	on	the	ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports	caused by	arriving and	departing	aircraft	will	be	reduced. The	CCO w/Wkm	M	and HH	BladeGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 14

350 QX3 AP UAS's do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight	operations.
**2.	The	Public	Will	Benefit	From	The	Safety	And	Efficiency	Of	The	CCO	W/Wkm M	and	HH	Blade**  **350 QX3**  **AP	UAS's.** Conducting aerial acquisitions with the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still photography flight operations. By using battery power and electric motors, the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft that are typically utilized foraerial video and photographywhile burning approximately 20

- 30 gallons per hour of leaded aviation fuel. The CCO w/Wkm M and HH Blade 350 QX3 AP UAS's, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UA's are propelled by battery powered electric motors,	rather	than	an	internal	combustion	engine.

By using the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's (weighing approximately 15 pounds 0 ounces and 4 pounds 0 ounces respectively, at their maximum gross weights with respectively (and with no fuel on board) has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds,	and	a	fuel	capacity	of	180	gallons. **3.	Performing Bridge	Ins** **pections	and Aerial	Video	and	Photography	Operations	With	The	CCO** 

**w/Wkm	M	and	HH	Blade	350 QX3**  **AP	UAS's	Will	Benefit	The	Economy.** In	addition	to	being	safe	and	efficient,	the	CCO	w/Wkm	M	and	HH	Blade	350 QX3 AP	UAS's	are	also	an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's will allow United States based companies, like Gowdy Brothers Aerospace 's to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and the Environmental Protection Agency (“EPA”) regulatory actions phasing outleaded aviation fuels, U.S. owned and operated compani es	must	adopt new and	alternative	technology	in	order to	remain	competitive.	Operating	the battery powered CCO w/Wkm M and HH Blade 350 QX3 AP UAS's is one such technology that notGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 15

only	allows	companies	greater	operational	flexibility	compared	to	manned	aircraft,	but	provides	such flexibility	withoutthe	high	operational	cost	of	a	traditional	manned	aircraft.

By operating the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's, companies such as Gowdy Brothers Aerospace's can remain competitive and profitable and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's, provides a stable workforce that increases consumer spending,	improves	local,	state,	and	federal	tax revenues	and	allows	companies	to	invest	in	research and	development	in	order	to	remain	competitive	both	in	the	United	States	and	abroad.

**4.There	Are	No	Pri vacy	Issues.** 
Similar to the manned aerial acquisition flight operations that have been conducted for decades, Gowdy	Brothers	Aerospace's	proposed	operation	of	the	CCO	w/Wkm	M	and	HH	Blade	350 QX3 AP UAS's will not implicate any privacy issues. Specifically, the CCO w/Wkm M And HH Blade 350 QX3 AP UAS's will be operated only in compliance with operating documents (i.e. Aerial Operations Manual, Monthly Maintenance Log, and the CCO w/Wkm M And HH Blade 350 QX3 AP Instruction Manual's) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of	14	C.F.	R.	§	91.119.



### E.	The	Reasons	Why	Granting	The	Exemption	Would	Not	Adversely	Af **fect Safety,	Or	How	The	Exemption	Would	Provide	A	Level	Of	Safety	At	Least	Equal**  **To	That	Provided	By	The	Rule	From	Which	Gowdy	Brothers	Aerospace	Seeks Exemption.**  **1.	Reasons	Why	The	CCO	w/Wkm	M	and	HH	Blade	350 QX3**  **AP	UAS's	Meet	The	Conditions	Of**

**The	FAA	M odernization	and	Reform	Act	of	2012	(FMRA)	Section	333.** 
In	consideration of	the	size, weight,	speed,	and	limited	operating	area	associated with	the	unmanned aircraft and its operation, Gowdy Brothers Aerospace's operation of the CCO w/Wkm M and HH Blade 3 50 QX3 AP UAS's meet the conditions of FMRA Section 333, and will not require an airworthiness	certificate	in	accordance	with	14	C.F.R.	Part	21,	Subpart	H. Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following,	in	part: (a) In General.

--Notwithstanding any other requirement of this subtitle, and not later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine ifGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 16 certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required	by	section	334	of	this	Act. (b) Assessment of Unmanned Aircraft Systems.

--In making the determination under subsection (a),	the	Secretary	shall	determine,	at	a	minimum

-- (1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national a irspace system or the public or pose	a	threat	to	national	security;	and (2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft	systems	identified	under	paragraph	(1). (c) Requirements for Safe Operation.

--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national	airspace	system. In	seeking	this	exemption,	Gowdy	Brothers	Aerospace	submits	that	the	CCO	w/Wkm	M	And	HH	Blade 350 QX3 UAS's can operate safely in	the	NAS	pursuant	to	FMRA Section 333, as demonstrated by: (a) the characteristics of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's; (b) the pilot certification requirement;	and	(c)	the	specific	operating	limitations.

**a. The	Specifications	Of	The	CCO	w/Wkm	M	and	HH	Blade	350**  **QX3 A** **P	UAS's	Demonstrate Its	Safe	Characteristics.**  The	CCO	w/Wkm	M	and	350 QX3 AP	UAS's	do	not	create	a	hazard	to	users	of	the	NAS	or	the	public,	or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.
**i.	Technical	Specifications	Of	The	CCO	w/Wkm	M	and	HH	Blade	350 QX3**  **AP	UAS's.**

The technical specifications of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's are set forth by the CCO w/Wkm M and HH Blade 350 QX3 AP Specifications and Data Sheet, attached hereto as Exhibit	A	and	B.
**ii.	The	CCO	w/Wkm	M	and	HH	Blade	350 QX3**  **AP	UAS's	Autonomous	Flight	And	Navigation**

**Modes	Enable	The	UAS's	To	Remain	Within	A	Defined	Operational	Area.**
The CCO w/Wkm M may be operated in both manual and fully autonomous flight modes. The HH Blade 350 QX3 AP may be operated in manual flight mode only. A complete description of the flight and navigational modes of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's is provided at pages 23

- 32	of	the	DJI	Wkm	M	and	pages	8	&	11	of	the	HH	Blade	350 QX3 AP	User	Manuals,	attached	hereto as	Exhibit	C	and	D.

**i ii.	The	CCO	w/Wkm	and	HH	Blade	350**  **QX3 AP	UAS's	Are	Designed	For	Automatic	Return	To**  **Home	Point	Or	Hover	In	The	Event	Of	Loss	Of	The	Control	Link	Or	Navigation.**Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 17

When the Control Link is lost, the CCO w/Wkm M UAS and HH Blade 350 QX3 AP will remain stationary in flight, for 3 seconds or more. If, after 3 seconds, the CCO w/Wkm M and HH Blade 350 QX3 AP due not reacquire control link data from the GCS, the UAS will assume that the Control Link is lost and the UAS will return to the home position (i.e., failsafe mode) via GPS, and will descend	to	the	takeoff	position	and	shutdown. A complete description of the Failsafe Functions of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's are set forth at pages 23 through 32 and for the Blade 350 QX3 AP at pages 8 and 11 of the CCO	w/Wkm	M	and	HH	Blade	350 QX3 AP	User	Manuals,	attached	hereto	as	Exhibit	C	and	D.

**iv.	The	CCO	w/Wkm	M	and	HH	Blade	350 QX3**  **AP	GCS	And	Its	Operation.**
A complete description of the operation and specifications of the CCO w/Wkm M and HH Blade 350 QX3 AP GCS and flight control software is provided at pages 23 through 32 of the DJI Wkm M User Manual and pages 8 and 11 of the HH Blade 350 QX3 AP User Manual. The CCO w/Wkm M and HH	Blade	350 QX3 AP	User	Manuals	are	attached	hereto	as Exhibits	C	and	D.
**b.	Flight	Operations	Of	CCO	w/Wkm	M	and	HH	Blade	350 QX3**  **AP	UAS's	Are	Limited	To	The**

**Line	Of	Sight	Of	A	Certificated	Pilot	in	Command	With	A	Safety	Observer.** Gowdy Brothers Aerospace will only utilize certificated pilots who possess a current and valid airman medical certificate to act as a pilot in command (PIC) of the CCO w/Wkm M And HH Blade 350 QX3 AP	UAS's.	Additionally,	a	safety	observer	will	assist	all	pilots	during	flight	time.
**c.	Flights	Of	CCO	w/Wkm	M	and	HH	Blade	350 QX3**  **AP	U AS's	Will	Be	Conducted	Pursuant	To**  **Specific	Operating	Limitations.**
In seeking this exemption, Gowdy Brothers Aerospace proposes to commercially operate CCO w/Wkm M and HH Blade 350 QX3 AP UAS's for the special purpose of bridge inspections and conducting aerial video and photography over certain areas of United States, pursuant to the following	specific	operating	limitations: 1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UAS's weighing less than 55 pounds maximum gross weight: CCO w/Wkm M and HH Blade 350 QX3 AP Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a petition to	amend	this	grant. 2. UAS operations under this exemption will be limited to conducting operations for the purpose	of	aerial	video	and	photography. 3. The	UA	may	not	be	flown	at	an	indicated	airspeed	exceeding	20	knots. 4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL), as	indicated	by	the	procedures	specified	in	the	operating	documents	unless	a	special	request is	made	and	approved	by	ATC.	All	altitudes	reported	to	ATC	must	be	in	feet	AGL. 5. The UA's must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses,	as	specified	on	the	PIC’s	FAA

- issued	airman	medical	certificate. 6. The	use	of	first	person	view	(FPV)	by	the	PIC	or	safety	observer	(SO)	is not	permitted.Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 18 7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO 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	SO	can	perform the	functions	prescribed	in	the	operating	documents. 8. The	SO	must	not	perform	any	other	duties	beyond	assisting	the	PIC	with	seeing	and	avoiding other air traffic and other ground based obstacles/obstructions and is not permitted to operate	the	camera	or	other	instruments. 9. The operating do cuments and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations contained in the grant of exemption and the procedures	outlined in the	operating	documents,	the	conditions	and	limitations	contained	in the	grant of exemption	take precedence	and	must be	followed.	Otherwise,	the operator	must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator upon request. The operator must	also	present	updated	and	revised	documents	if	it	petitions	for	extension or	amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted	if	questions	arise	regarding	updates	or	revisions	to	the	operating	documents. 10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a	condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented	in	the	aircraft	records. 11. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the	aircraft	records. 12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating	documents. 13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, overhaul,	replacement,	inspection,	and	life	limit	requirements. 14. The	operator	must	carry	out	its	maintenance,	inspections,	and	record	keeping	requirements, in accordance with the operating documents, maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized	person	returning	the	UAS	to	service. 15. Each UAS's operated under this exemption must comply with all manufacturer Safety Bulletins. 16. The authorized person must make an entry in the aircraft record of the corrective action taken	against	discrepancies	discovered	between	inspections. 17. The PIC must possess at least a private pilot certificate and at least a current third

- class medical	certificate. 18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. §61.51(b). Flights for the purposes of training the operator’s PIC's are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

-Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 19 building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants	in	accordance	with	14	C.F.R.	§	91.119. 19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is	required,	a	special	request will	be	made	at	the	FAA	office	closest	to	proposed	area of operations.	Flights	under	special	visual	flight	rules	(SVFR)	are	not	authorized. 20. The	UA	may	not	operate	within	5	nautical	miles	of	an	airport	reference	point	as	denoted	on	a current FAA published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be	made	available	to	the	Administrator	upon	request. 21. 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	from	the	PIC. 22. If the UA loses communications or loses its GPS signal, it must return to a pre- determined location within the planned operating area and land or be recovered in accordance with the operating	documents. 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance	with	the	operating	documents. 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point	and	land	the	UAS	with	25%	battery	power	remaining. 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA	will	also require the	operator	to request	a	Notice	to	Airman	(NOTAM) not	more than	72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including clas s of	airspace,	altitude	level	and	potential	transponder	requirements. 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as large as practicable. 27. Before conducting operations, the radio frequency spectrum used for operation and control of the UAS must comply with the Federal Communications Commission (FCC) or other appropriate	government	oversight	agency	requirements. 28. The	documents	required	fewer	than	14	C.F.R.	91.9	and	91.203	must	be	available	to	the	PIC	at the	Ground	Control	Station of	the	UAS	any time	the	UAS	is	operating.	These	documents	must be	made	available	to	the	Administrator	or	any	law	enforcement	official	upon	request. 29. The UAS must remain clear and yield the right of way to	all	manned aviation operations and activities	at	all	times. 30. The	UAS	may	not	be	operated	by	the	PIC	from	any	moving	device or	vehicle. 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and	structures	unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UAS and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where	nonparticipating	persons	leave	such protection	and	are	within	500	feet	of	the UA,	flight	operations	must	cease	immediately	and/or; b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of	such	vessels,	vehicles	or	structures has	granted permission	and the PIC	has	made	a	safety	assessment of	the risk	of	operating	closer	to	those objects and	determined	that	it	does	not	present	an	undue	hazard,	and; c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present	an	undue	hazard	to	tho se	persons	per	§	91.119(a).Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 20 32. All operations shall be conducted over private or controlled

-access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for each flight to be conducted. 33. Any	incident,	accident,	or	flight	operation	that	transgresses	the	lateral	or	vertical	boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. **2.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	61.113(a)	And	(b)	Would Not	Ad** **versely	Affect	Safety.** Gowdy Brothers Aerospace submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's unless that PIC has demonstrated, by meeting minimum flight

-hour and currency requirements, that the PIC is able to safely operate the CCO w/Wkm M or HH Blade 350 QX3 AP UAS in a manner consistent with the exemption, including evasive and emergency maneuvers	and	maintaining	appropriate	distances	from	people,	vessels,	vehicles	and	structures. Considering Gowdy Brothers Aerospace's proposed area of operations, and the operating limitations set forth

-above; the parallel nature of private pilot aeronautical knowledge requirements to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship skills necessary to safely operate the CCO w/Wkm M or HH Blade 350 QX3 AP UAS, Gowdy Brothers Aerospace submits that the additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for Gowdy Brothers Aerospace's specific proposed flight operations. The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances	similar,	in	all	material	respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156,	11158,	11159,	11160,	11161,	11445). Gowdy	Brothers	Aerospace	will	not	allow	any	PIC	to	operate	the	CCO	w/Wkm	M	or	HH	Blade	350 QX3 AP UAS unless that PIC has demonstrated, by meeting minimum flight

-hour requirements of the CCO w/Wkm M or HH Blade 350 QX3 AP UAS training and currency requirements, that the PIC is able to safely operate the CCO w/Wkm M or HH Blade 350 QX3 AP UAS in a manner consistent with this exemption,	including	evasive	and	emergency	maneuvers	and	maintaining	appropriate	distances	from people,	vessels,	vehicles	and	structures. Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours

as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption).	In	addition	to	the	hour	requirements,	the	PIC	must	accomplish	3	takeoffs	and	landings	in the	preceding	90	days	(for	currency	purposes).Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 21

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during Gowdy Brothers Aerospace's proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure	safe	operations,	stating	as	follows: In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated and logged, in a
manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least	10	hours	logged	as	a	UAS	pilot	with	a	multi

- rotor	UAS.	Prior	to operations	under	Exemption	No. 11062, the PIC must also have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for

currency	purposes).	The	FAA	finds	that	at	a	minimum,	the	flight

-hour	requirements	in	Exemption	No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that

was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

-building flights can also be conducted under the grant of exemption to accomplish the required flight time. During training, proficiency, and experience

-building flights the PIC	is	required	to	operate	the	UA	with	appropriate	distances	in	accordance	with	14	C.F.R	91.119. Exemption	No.	11138	at	page	15.
Accordingly, Gowdy Brothers Aerospace will ensure safe operations by not allowing any PIC to operate the CCO w/Wkm M or HH Blade 350 QX3 AP UAS unless that PIC has demonstrated, by meeting minimum flight

-hour and currency requirements, that the PIC is able to safely operate the CCO w/Wkm M or HH Blade 350 QX3 AP UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles	and	structures. **3.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.7(a) Would	Not**  **Adversely	Affect	Safety.**
The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, Gowdy Brothers Aerospace will ensure that the CCO w/Wkm M or HH Blade 350 QX3 AP UAS	is	in	an	airworthy	condition based	upon	the	UAS’s	compliance	with	its	operating	documents	and

as stated in the conditions and limitations herein. Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in circumstances similar, in all material respects, to thoseGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 22

presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,	11112,	11136,	11138,	11150,	11153,	11156,	11157,	11158,	11159,	11160,	11161). **4.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Sect ion	91.121	Would	Not**  **Adversely	Affect	Safety.**
The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's will be provided to the PIC via GPS	equipment	and	a	radio	communications	telemetry	data	link,	which	downlinks	from	the	UA	to	the GCS for active monitoring of the flight path and altitude. This altitude information, combined with Gowdy Brothers Aerospace's operation of the CCO w/Wkm M and HH Blade 350 QX3 AP UA's within visual	line	of	sight,	at	or	below	400	feet	AGL,	will	ensure	a	level	of	safety	equivalent	to	Section	91.121. The	altitude	information	will	be	generated by	GPS	equipment installed	on board	the aircraft. Prior	to each flight, a zero altitude initiation point is automatically established by the UAS's at ground level. The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar,	in	all	material	respects,	to	those	presented	herein	(e.g.	Exemption	Nos.	11062, 11063,	11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159,	11160,	11161,	11445). **5.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Section	91.151(b)	Would	Not Adversely	Affect	Safety.** 
A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the CCO W/Wkm M and HH Blade 350 QX3 AP UAS's; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. Accordingly, Gowdy Brothers Aerospace will ensure that he will safely operate the battery powered CCO w/Wkm M and HH Blade 350 QX3 AP UA's during daylight hours in VFR conditions, with enough battery power to fly for a total duration of 10 minutes to the first point of intended landing	and,	assuming	normal	cruising	speed,	to	fly	after	that	for	at	least	2.5	minutes. Here, as in Exemption No. 11109, the technical specifications of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's the limitations on the propos ed flight operations and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's provide audible	and	visual	warnings to	the	PIC	at the	GCS when	the	UA's	experiences	low	battery	voltage,	the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining battery power. At the critically low battery level, the CCO w/Wkm M and HH Blade 350 QX3 AP	UAS's	will	descend	and	land	automatically.
Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely affected when the technical characteristics and operating limitations of theGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 23

UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from Section 91.151 specific to UAS in circumstances similar in all material respects to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11 110, 11136, 11138,	11150,	11153,	11156,	11157,	11158,	11159,	11160,	11161,	11445).
**6.	Reasons	Why	An	Exemption	From	The	Requirements	Of	Sections	91.405(a),	91.407(a)(1), 91.409(a)(1)	&	(a)(2),	And	91.417(a)	&(b)	Would	Not	Adversely	Affect	Safety.** 
In	seeking	this	exemption,	Gowdy	Brothers	Aerospace	submits	that	the	equivalent	level	of	safety	with regard	to	the	regulatory	maintenance	and	alteration	requirements	established	by	Sections	91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because Gowdy Brothers Aerospace will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UAS's using the methods, techniques, and practices prescribed in the operating documents i.e., the Operations Manual, Monthly Maintenance Log, and CCO w/Wkm M and HH Blade 350 QX3 AP Instruction Manual. Furthermore, Gowdy Brothers Aerospace will document and maintain	all	maintenance	records	for	the	CCO	w/Wkm	M	and	HH	Blade	350 QX3 AP	UAS's. Since the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's will be inspected as prescribed by the operating documents, Gowdy Brothers Aerospace will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the CCO w/Wkm M	and HH	Blade 350 QX3 AP	User	Manuals	are	attached	hereto	as	Exhibit	C	and	D;	a	copy	of	the	CCO	w/Wkm M	and	HH	Blade	350 QX3 AP	UAS	Maintenance	LOG	is	attached	hereto	as	Exhibit	E. Likewise, the exemption sought will not adversely affect safety because Gowdy Brothers Aerospace will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS	using	the	methods,	techniques,	and	practices	prescribed	by	the	operating	documents.

Furthermore, the exemption sought would maintain an equivalent level of safety Established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's will be performed by trained technicians. Maintenance will be documented and	maintained	utilizing	the	monthly	maintenance	log.
Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely affected when the technical	characteristics	and	operating	limitations	of	the	UAS	are	considered.

In consideration of Gowdy Brothers Aerospace's proposed operating limitations, the operating documents, and the technical aspects of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's, Gowdy Brothers	Aerospace	submits	that	safety	will	not	be	adversely	affected	by	granting	exemption	from	14Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 24

C.F.R.	Sections	91.405(a),	91.407(a)(1)	and	(a)(2),	91.409(a)	(2),	and	91.417(a)	and (b).	The	FAA	has previously granted relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110,	11112,	11136,	11138,	11150,	11153,	11156,	11157,	11158,	11159,	11160,	11161,	11445).

**7.	The	FAA	May	Prescribe	Any	Other	Condition s	For	Safe	Operation.** 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R.	§	21.16	entitled	Special	Conditions,	Gowdy	Brothers	Aerospace	requests	that	the	FAA	prescribe special	conditions for	the	intended	operation of	the	CCO w/Wkm	M	And	HH	Blade	350 QX3 AP	UAS's, which contain such safety standards that the administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§	61.113(a) & (b), 91.7	(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).	Such special conditions will permit safe operation of the UA's for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements	that	must	be	established	for	the	safe	operation	of	the	UAS	in	the	NAS. Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. §21.1 6, for operation	of	the	CCO	w/Wkm	M	and	HH	Blade	350 QX3 AP	UAS's,	since the	airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions, states the following: If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design	feature	of	the	aircraft,	aircraft	engine	or	propeller,	it	may	prescribe	special	conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the	FAA	finds	necessary	to	establish	a	level	of	safety	equivalent	to	that	established	in	the	regulations. See 14 C.F.R. § 21.16. Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Gowdy Brothers Aerospace's intended operation of the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's, which contain such safety standards that the administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 25



### F.	A	Summary	That	Can	Be	Published	In	The	Federal	Register	stating:	The **Rule s	From	Which	Gowdy	Brothers	Aerospace	Seeks	Exemption:**  Gowdy Brothers Aerospace seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a),	91.121,	91.151(b),	91.405(a),	91.407(a)(1),	91.409(a)(1)	&	(a)(2),	and	91.417(a)	&	(b).



### A **Brief	Description	Of	The	Nature	Of	The	Exemption	Gowdy	Brothers Aerospace	Seeks:** 
This exemption will permit Gowdy Brothers Aerospace to commercially operate an Unmanned Aircraft System (UAS) for the purpose of bridge inspections and conducting aerial video and photography over certain	areas	of	the	United	States.



### G.	Any	Additional	Information,	Views,	Or	Arguments	Available	To	Support

**Gowdy	Brothers	Aerospace's	Request.**

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, Gowdy Brothers Aerospace request for exemption may be granted pursuant to the authority	of	FMRA	Section	333	and	14	C.F.R.	Part	11,	as	set	forth	above. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to
users of the NAS or the public, or otherwise poses a threat to national security and further, provides the	authority	for	such	UAS	to	operate	without	airworthiness	certification. As discussed in detail above, Gowdy Brothers Aerospace will operate the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's safely in the NAS, without creating a hazard to users of the NAS, or the public,	or	otherwise	pose a	threat	to	national	security.


## CONCLUSION As	set	forth	herein,	Gowdy	Brothers	Aerospace	seeks	an exemption	pursuant	to	14	C.F.R.	§	11.61	and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the CC O w/Wkm M and HH Blade 350 QX3 AP UAS's commercially, without an airworthiness certificate, for the limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing Gowdy Brothers Aerospace to safely, efficiently, and economically operate the CCO w/Wkm M and HH Blade 350 QX3 AP UAS's commercially	within	the	NAS.Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 26

**WHEREFORE**, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, Gowdy Brothers Aerospace respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a)	&	(b),	and permit Gowdy	Brothers	Aerospace to	operate	the	CCO	w/Wkm M	and	HH	Blade 350 QX3 AP UAS's commercially for the purpose of bridge inspections and conducting aerial video and	photography	over	certain	areas	of	the	United	States.

Dated: April	30,	2015
Respectfully	submitted,

Stephen	C.	Gowdy Gowdy	Brothers	AerospaceGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 27 

## APPEND**ICES:**

**A**
**- CCO	w/Wkm	M	Specifications** 
**B**
**– HH	Blade	350**  **QX3 AP	Specifications** 
**C**
**- DJI	Wkm	M	User	Manual** 
**D**
**– HH	Blade	350**  **QX3 AP	User	Manual** 
**E**
**- Monthly	Maint** **en ance	Log** Gowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 28 

## APPENDIX
**– A**  **CCO	w/Wkm	M	TECHNICAL	SPECIFICATIONS**
Gowdy	Brothers	Aerospace	only utilizes	safe	and	reliable	UAS's.	DJI	is	an	industry	leader	in	small	UAS production. DJI UAS's are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

-time altitude and location information to the PIC via the	linked	monitor,	Spektrum	DX	9	Radio	Control	Transmitter 1.1	CCO	w/Wkm	M 1.1.1	Aircraft 1.1.1.1	Batteries

– (2)Thunder	Power	5000mAH	LiPo	Battery 1.1.1.2	Weight,	Flight

– 7	lbs

. 6	oz

. (3345g) 1.1.1.3	Hover	Accuracy

–Vertical:	+/

- .5m;	Horizontal:	+/

- 2m 1.1.1.4	Max	Tilt	Angel

- 35deg 1.1 .1.5	Max	Ascent/Descent	Speed

– 6m/s 1.1.1.6	Max	Flight	Speed

– 15m/s	(NOT	RECOMMENDED) 1.1.2	Gimbal 1.1.2.1	Photohigher	AV200	w/360	Pan 1.1.2.2	Controller – Hoverfly	Gimbal	3Axis	Control	Board 1.1.2.3	Battery	2700mAh	2s 1.1.2.4	Pan

- Controllable	360deg 1.1.2.5	Pitch

- Controllable

- 90deg 1.1.2.6	Horizon

– Automatic 1.1.3	Transmitter	FPV	(CAMERA	OPERATOR	ONLY) 1.1.3.1	Immersion	RC	5.8GHz	AV 1.1.3.2	Power	Out

-put	600mW	28dBm	+/

- 1dBm 1.1.3.3	Frequencies	5740,	5760,	5780,	5800,	5820,	5840	and	5860MHz 1.1.4 Camera 1.1.4.1	Canon 1.1.4.2	EOS	60	D 1.1.4.3	Effective	Pixels

– 18M 1.1.4.4	Operating	Temperature	Range

- 32deg	F	/ 104deg	F 1.1.5 Transmitter	1	Aircraft 1.1.5.1	Spektrum	DX9 1.1.5.2	Operating	Frequency	2.400GHz

– 2.4835GHz 1.1.5.3	Communication	Distance	(unobstructed)	FCC	Compliance	800m 1.1.5.4	Transmitter	Power	FCC	Compliance	100mW 1.1.5.5	Battery	2000mAh	Li

-lon	2S 1.1.5.6	Operating	Temperature

- 14deg	to	104deg	F 1.1.6	Transmitter	2	Gimbal 1.1.6.1	Spektrum	DX8 1.1.6.2	Operating	Frequency	2.400GHz

– 2.4835GHz 1.1.6.3	Communication	Distance	(unobstructed)	FCC	Compliance	800m 1.1.6.4	Transmitter	Power	FCC	Compliance	100mW 1.1.6.5	Battery	2000mAh	NiMH	4S 1.1.6.6	Operating Temperature

- 14deg	to	104deg	FGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 29 

### APPENDIX
**– B** 


## HH	Blade	3 **50QX3	AP	TECHNICAL	SPECIFICATIONS**
Gowdy Brothers Aerospace only utilizes safe and reliable UAS's. HH is an industry leader in small UAS production. HH UAS's are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and	set	distance.	In	addition,	HH	software provides	real

-time	altitude	and	location	information	to the PIC	via	the	linked	RC	Control	Transmitter. 2.2	HH	Blade	350 QX3 AP 2.2.1	Aircraft2.2.1.1	Battery

– Thunderpower	3300	mAh	LiPo 2.2.1.2	Weight	(Battery	Included)

– 2	lbs	3.5oz	(1006g) 2.2.1.3	Hovering	Accuracy	(GPS	Mode)

–Vertical:	0.5m;	Horizontal:	2.5m 2.2.1.4	Max	Angular	Velocity

– Pitch:	3000/s;	Yaw:	1500/s 2.2.1.5	Max	Tilt	Angle

- 350 2.2.1.6	Max	Ascent	Speed

– 5m/s 2.2.1.7	Max	Descent	Speed

– 4m/s 2.2.1.8	Max	Speed

– 22m/s	(ATTI	mode,	no	wind

– NOT	RECOMMENDED) 2.2.1.9	Max	Flight	Altitude

– 4500m 2.2.1.10	Max	Wind	Resistance

– 10m/s 2.2.1.11	Max	Flight	Time

–Approximately	13	minutes 2.2.2	Gimbal 2.2.2.1	Model

– Blade	GB200	2	Axis	Brushless	Gimbal 2.2.2.2	Controllable	Range	0	deg	to

- 90deg 2.2.2.3	Horizon

- Automatic 2.2.2.4	Operating	Temp

- 32deg	to	140	F 2.2.3	Camera 2.2.3.1	Name

– GoPro 2.2.3.2	Model

– Hero	3	Silver 2.2.3.3	Pixel	11M 2.2.4	Transmitter 2.2.4.1	Spektrum	DX9 2.2.4.2	Operating	Frequency	2.400GHz	to	2.4835	GHz 2.2.4.3	Communication	Distance	(unobstructed)	FCC Compliance	800M 2.2.4.4	Transmitter	Power	FCC	Compliance	100mW 2. 2.4.5	Battery	2000mAh	2S	Li

-lon	2S 2.2.4.6 Operating Temperature

- 14deg	to	104deg	FGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 30 **APPENDIX**
**– C**  

## DJI	Wkm	M

**– Manufacturer's	User	Manual** 


## http://www.dji.com/product/wookong

-mGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 31 **APPENDIX**
**– D**  

## HH	Blade	350QX3	AP	Manufacturer’s	User	Manual
http://www.horizonhobby.com/pdf/BLH8100

- Manual

- EN.pdfGowdy	Brothers	Aerospace,	LLC						Section	333	Exemption	Submission version	1.0 April	30,	2015 Page 32 **APPENDIX**
**– E**  

## Gowdy	Brothers	Aerospace	Monthly	Maintenance	and	Repair	Log

Gowdy	Brothers	Aerospace	will	be	using	and	individual	fight	time,	monthly	maintenance	and	repair log	book	for	each	unit	in	operation	the	following	is	an	example	of	the	minimum	logged	information:
Aircraft: N

- Number: Hours: Date:
Date	Issue

Discovered Date	Issue

Resolved Issue Description/

Maintenance Conducted Repair/Maintance Performed	By
Airframe Motors Propellers Flight	Control	Update Gimbal Misc