# Blue Goose Construction

U. S. Department ofTransportation Docket Management System 1200 New Jersey Ave., SE Washington, D.C. 20590 Blue Goose Construction LLC Section 333 Petition to Operate Small Unmanned Aerial Systems Prepared By: Scott Holmes 9901 Okeechobee Road Fort Pierce, FL 34945 (772)461-3020 sholmes@bluegooseconstruction.com

Petition Summary: State Certified Licensed General Contractor #CGC1517686 Pollutant System Contractor # PCC056727 Underground Utility & Excavation # CUC 1225110

Pursuant to Section 333 ofthe FAA Moderation and Reform Act of2012, Pub. L. No. 112-95 (2012), 126 Stat. 11 ("Section 333") and the Federal Aviation Administration's (FAA") general Exemption authority under 49 U.S.C. section 44701(f), Scott Holmes ("Petitioner") hereby petitions for exemptions from 14 C.F. R. Part 21, Subpart H (Airworthiness Certificates), 14 C.F.R. Part 27. (Airworthiness Standards: Normal Category Rotocraft), 14 C.F.R. sections 61.113(A)- (b),91.103(b)(1 ), 91.119(c), 91.121, 91.151, 91.405(a)(l), 91.409(a)(2), and 91.417(a)-(b). The proposed exemption, ifgranted, would allow Petitioner to conduct commercial operations of Small unmanned aircraft systems ("UAS") meeting or exceeding all ofthe operational and safety Requirements Congress has set forth in Section 333. Petitioner is a Civil Construction companythat plans to exploit the capabilities ofUnmanned Aerial Systems to offer a multitude ofservices, including:

• Aerial Surveying • Remote Sensing • Telecommunications • Agriculture • Aerial filmmaking and photography

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### *FtPierce, FL 34979-4709 *Ph. (772) 461-3020 *Fax: (772) 468-4669• Energy systems inspections and monitoring • Wildlife and Forestry monitoring • Educational and research operations • Pipeline inspection and patrolling • Infrastructure Inspections Statutory Authority: Page2 8128115

Section 333, titled "Special Rules for Certain Unmanned Aircraft Systems", provides a mechanism for seeking expedited FAA authorization ofsafe civil UAS operations in the NAS. Section 333(a) Statesthat the FAA "shall determine ifcertain unmanned aircraft systems may operate safely in the national airspace systembefore completion ofthe (comprehensive) plan and rulemaking required by section 332(b)(l) ofthis Act orthe guidance required by section 334 ofthisAct". In Section 332 (b)(l), Congress made it clear that Section 333 provides a mechanism for "expedited operation authorization" ifseveral factors are met. Petitioner meets all requirements to permit FAA approval ofcommercial UAS operations. The Petitioner Requests Relieffrom the Following: Section 61.113(a) and (b) prescribes that- (a) No person who holds a private pilot certificate may act as a pilot in command ofan aircraft that is carrying passengers orproperty for compensation orhire; nor maythat person, for compensation orhire, act as pilot in command ofan aircraft. (b) A private pilot may, for compensation orhire, act as pilot in command ofan aircraft in connection with anybusiness or employment if: 1. The flight is only incidental to that business oremployment; and 2. The aircraft does not carrypassengers orproperty for compensation orhire. Section 91.103 prescribes, in pertinent part, that eachpilot in command shall, beforebeginning a flight, become familiar with all available information concerning that flight, to include

- (a) For a flight under IFR or a flight not in the vicinity ofan airport, weather reports and forecasts, fuel requirements, alternatives available ifthe planned flight cannot be completed, and any known traffic delays ofwhichthe pilot in command has been advised byATC; (b) For any flight, runway lengths at airports ofintended use, and the following takeoffand landing distance information: 1. For civil aircraft for which an approved Airplane orRotocraft Flight Manual containing takeoffand landing distance data is required, the takeoffand landing distance data contained therein; 2. For civil aircraft other than those specified in paragraph (b)(l) ofthis section, otherreliable information appropriate to the aircraft, relating to aircraft performance under expected values ofairport elevation and runway slope, aircraft gross weight, and wind and temperature. Section 91.119 prescribes that, except when necessary for takeofforlanding, no person may operate an aircraft below the following altitudes:

P.O. Box 14709 

### *FtPierce, FL 34979-4709 *Ph. (772) 461-3020 *Fax: (772) 468-4669Page3 8128115 (a) Anywhere. An altitude allowing, ifa power unit fails, an emergency landing without undue hazard to persons orproperty onthe surface. (b) Over congested areas. Over any congested area ofa city, town, or settlement, orover any open air assembly ofpersons, an altitude of1,000 feet above the highest obstacle within a horizontal radius of2,000 feet ofthe aircraft. (c) Over otherthan congested areas. An altitude of500 feet above the surface, except over open water or sparsely populated areas. Inthose cases, the aircraft maynot be operated closerthan 500 feet to any person,**vesse~** vehicle, or structure. (d) Helicopters, powered parachutes, and weight-shift-control aircraft. lfthe operation is conducted without hazard to persons orpropertyonthe surface

- 1. A helicoptermaybe operated at less than the minimums prescribed in paragraph (b)or (c) of this section, provided eachperson operating the helicopter complies with anyroutes or altitudes specifically prescribed for helicopters bythe FAA; and 2. A powered parachute orweight-shift-control aircraft maybe operated at less thanthe minimums prescribed in paragraph© ofthis section. Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude byreference to an altimeterthat is set "to the elevation ofthe departure airport or an appropriate altimeter setting available before departure". Section 91.151(a) prescribes that no person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended and assuming normal cruising speed. (1) during the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes. (emphasis added) Section 91.405 (a) requires, in pertinent part, that an aircraft operatororowner shall have that aircraft inspected as prescribed in subpart E ofthe same part and shall, betweenrequired inspections, except as provided in paragraph (c) ofthe same section, have discrepancies repaired as prescribed in part 43 ofthe chapter. Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved for returnto service bya person authorized under Section 43.7 ofthe same chapter. Section409(a)(2) prescribes, in pertinent part, that no personmay operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance ofan ofan airworthiness certificate in accordance withpart 21 ofthis chapter. Section 91.417(a) and (b) prescribes, in pertinent part, that- (a) Eachregistered owner oroperator shall keep the following records for the periods specified in paragraph (b) ofthis section: 1. Records ofthe maintenance, preventative maintenance, and alteration and record ofthe 100- hour, annual, progressive, and other required or approved inspection, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. The records must include

-

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### *FtPierce, FL 34979-4709 *Ph. (772) 461-3020 *Fax: (772) 468-4669Page4 8128115

1. A description (orreference to data acceptable to the Administrator) ofthe work performed; and ii. The date ofcompletion ofthe workperformed; and 111. The signature, and certificate number ofthe person approving the aircraft for return to service. 2. Records containing the following information: i. The total time in service ofthe airframe, each engine, eachpropeller, and eachrotor. ii. The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. 111. The time since last overhaul ofall items installed onthe aircraft which are required to be overhauled on a specified time basis. tv. The current inspection status ofthe aircraft, including the time since the last inspection required bythe inspection programunder whichthe aircraft and its appliances are maintained. v. The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD or safety directive involves recurring action, thetime and date when the next action is required. vt. Copies ofthe forms prescribed by Section43.9(d) ofthis 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. Therecords specified inparagraph (a)(1) ofthis section shall beretained until the work is repeated or superseded byother workor for 1 year after the workis performed. 2. Therecords specified in paragraph (a)(2) ofthis section shall beretained and transferred with the aircraft at thetime the aircraft is sold. 3. A list ofdefects furnished to a registered owner oroperatorunder Section 43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to service 

### UnmannedAircraft System The Petitioner states that the unmanned aircraft(s) (UA) to be operated underthis request is less than 55 lbs. fully loaded, flies at a speed ofno more than 50 knots, carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a secured areas as set out in the POH. The crafts are as listed: • (2) Steadi Drone QU40 2014- four blade craft, four motorVTOL design, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. • (2) Sensefly ebee- fixed wing, forward flight only, single motor design, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. • Birds Eye View Aerobotics- FireFLY 6- 6 blade craft, three motorVTOL design, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. • DJI Phantom4

- four blade craft, four motor VTOL design, GPS, full autonomous autopilot capabilities, telemetry and manual ground control. In addition, the above listed crafts have integrated safety features built into the design ofthe UAS, as described in the POH, to ensure the safety ofpersons and propertywithin and surrounding the

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limited operating area. The Petitioner further describes that, inthe event theUAS loses communications orits GPS signal, the UAwill have the capability to returnto a pre-determined location within the SecurityPerimeter and land. Itwill also have the capability to abort a flight in the event ofunpredicted obstacles or emergencies. Pre-llight Inspection, Maintenance Before each flight the PIC will perform a series ofpre-flight and takeoffchecks as determined by the POH supplied. After each 60 minutes ofairtime, the craft will undergo a thorough inspection ofall aircraft components, including, but not limited to: a. Actuators 

### I Servos b. Motors, wiring and connectors c. Propellers/Wings, smooth, no chips d. Electronic speed controller, wiring and connectors e. Batteries, wiring and connectors f. Remote command and control g. Ground control station UAS Operating Parameters The Petitioner states that all flights will be operated with visual line ofsight (VLOS) ifpilot, in daytime VFR flight conditions and all operations willbe conducted withthe assistance ofa second spotter/observer. The UAS flights will be limited to a maximum altitude of4oo feet AGL. Altitude is accurately measured by GPS. The Petitioner further states that an operatorwill ensure that only consenting productionpersonnel will be allowed within 100 feet ofthe UA operation, and UAS will bekept at least 100 feet from any inhabited structure. Generally, the Petitioner's UAS will be operated in rural or suburban areas that will permit significantly larger safety zones. Flight Standards District Offices (FSDOs) will be notified, as required, priorto operationto describe intended coordination for proposed operation(s). Petitioner will obtain anAir Traffic Organization ("ATO") issued Certificate ofWaiverorAuthorization ("COA'') priorto conducting any operations under this grant ofexemption. In fulfilling its requirements under the COA, Petitioner will berequired to request a NOT AMnot more than 72 hours in advance, but not less than 48 hours to the operation. Petitioner's UAS will remain clear and yield the right ofwayto all manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, and hangliders). Petitioner will not conduct UAS operations within 5 nautical miles ofthe geographic center ofa non-towered airport unless a letterofagreement withthat airport's management is obtained and the operation is conducted in accordance with a Notice to Airman (''NOTAM"). Pilot in Command (PIC) The Pilot in Command will beJames Wise. Hereceived his Private Pilot License with MultiEngine and Instrument Rating and has logged more than 200 hours in fixed wing types ofaircraft. (Certification#3498396)

P.O. Box 14709 

### *FtPierce, FL 34979-4709 *Ph. (772) 461-3020 *Fax: (772) 468-4669Page 6 8128115 Regarding Petitioner's requested relieffrom 14 C.F.R Section 91.103(b)(1), Petitioner will comply with the other applicable procedures and requirements stated in Section 91.103(a) and (b). Specifically, the PIC will take all actions including reviewing weather, flight batteryrequirements, aircraft performance data, and landing and takeoffdistances before initiation ofa flight. The PIC will also account for all relevant site-specific conditions in their preflight procedures. Risks presentedby sun glare will be mitigated bythe PIC's and YO's ability to see other air traffic and initiate a return-to-home sequence ifneeded. Radio Frequencies Radio frequencies used will bethose allottedbythe FCC for datatransmission and vehicle control in unlicensed frequency bands. All devices used will comply with FCC usage and emissions regulation. Safety Benefits ofthe UAS The Petitioner will beusing the UAS in a variety ofapplications that generallyrequire expensive full-sized manned aircraft to complete. Small, light, unmanned aerial vehicles offer myriad benefits overthe use offull-sized manned aircraft for inspection oflarge civil construction sites, electric power lines inspection, advanced agriculture, film and still photography,justto name a few. Replacing significantly larger manned aircraft carrying crew and flammable fuel with small UAS carrying no passengers or crew creates a much greater margin ofsafety for the pilots and crew. Bygranting Petitioner's requested exemptions, the FAA will help drive development ofsafe and successful commercial UAS operations and will advance the public knowledge base for such operation. Petitioner is committed to promoting the UAS research efforts ofpolicymakers including the FAA, NASA, DOD, and DARPAby sharing data from its commercial UAS operations and serving as a resource for suture UAS research operation. Thus, the FAA has good cause to grant this Petition. Conclusion Forthe foregoing reason, the exemptions requested herein should be granted and Petitioner should bepermitted to conduct small UAS operations in accordance with its manuals and all other operating parameters deemed necessary and appropriate bythe FAA

P.O. Box 14709 

### *FtPierce, FL 34979-4709 *Ph. (772) 461-3020 *Fax: (772) 468-4669