# Private and Confidential

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

Ruchek UAS Services - Section 333 Exemption Petition

02/24/2016

Re: Exemption Request Section 333 of the FAA Reform Act of the Federal Aviation Regulations from 14 C.F.R. 45.23(b); 14 C.F.R. Part 21; 14 C.F.R. 61.113(a)&(b); 91.7(a); 91.9(b) (2); 91.103(b); 91.109; 119.121; 91.151(a); 91.203(a)&(b); 91.405(a); 91.407(a) (1); 91.409(a) (2); 91.417(a)&(b)

Dear Sir or Madam,

Pursuant to section 333 of the FAA Modernization and Reform Act of 2012 (The Reform Act) and 14 C.F.R Part 11, Ruchek UAS Services, operator of Small Unmanned Aircraft Systems (sUAS) intends to offer On Demand Commercial UAS operations for a variety of industries and applications for both public and private.

Ruchek UAS Services hereby applies for an exemption from the listed Federal Aviation Regulations ("FARs") to allow commercial operation of its sUAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.

Following exemption and approval by the FAA, Ruchek UAS Services, will use my professionally built DJI Phantom 2, DJI Phantom 3, DJI Inspire 1, DJI Spreading Wings S800, DJI Spreading Wings S900, DJI Spreading Wings S1000, Freefly ALTA, 3D Robotics X8, 3D Robotics Iris, 3D Robotics Solo, SenseFly eBee, Yuneec Q500 Typhoon, and Yuneec H920 Tornado when each weighing less than 55 pounds including payload which includes cameras and other data collecting technology for the following applications:

Search and Rescue Education Utility-power transmission system(s) patrolling and inspection Pipeline monitoring, patrolling and inspection Construction site monitoring, inspection and patrolling Commercial building/real estate monitoring and inspections2

2 Residential building/real estate inspections Hydro-electric dam structure monitoring, patrolling and inspection Wind turbines monitoring, patrolling and inspection Cell Tower inspection and monitoring Underground infrastructure monitoring, patrolling and inspection Agricultural monitoring, patrolling and inspection Bridge construction/maintenance patrolling and inspection Aerial surveying/mapping Public Entity Support Operations Indoor and outdoor filmmaking, cinematography, and videography Forestry and wildlife monitoring Underground infrastructure monitoring and inspection and similar types of operations, both public and private

Ruchek UAS Services exemption request would permit the operation of lightweight, unmanned (i.e. piloted by remote control) sUAS’s for the development of community and government use permissible within property boundaries for individual homeowners and within in tightly controlled, limited airspaces predetermined in areas away from the general public, airports, heliports and vehicular traffic. Currently, similar lightweight, remote controlled UAS's are legally operated by unmonitored amateur hobbyists with no safety plan or controls in place to prevent catastrophe. Furthermore, it is my intent to assist future FAA safety protocols and regulations exclusive to lightweight sUAS's by sharing information with the FAA as I record flight data and other pertinent information gained through permitted flight operations.

In addition, granting Ruchek UAS Services an exemption request will comply with the Secretary of Transportation’s (FAA Administrator’s) instructions to not only integrate sUAS's into the national airspace system, but to “...establish requirements for the safe operation of such aircraft systems [UAS's] in the national airspace system” under Section 333(c) of the Reform Act specific to the use of UAS's for real estate/Realtor purposes, educational videos, Search and Rescue, land/trusts inspections, agricultural field monitoring, film/video productions, closed-set motion picture film operations and television, and structure inspections, to aid state and local agencies. Further, Ruchek UAS Services will conduct my operations in compliance with the protocols described herein or as otherwise established by the FAA.

For the reasons stated below, Ruchek UAS Services respectfully request the grant of an exemption allowing me to operate lightweight , remote controlled sUAS’s to aid in academic community awareness, to benefit and stimulate attraction to the Greater Sacramento, California region and to enhance personal and public sUAS safety. A grant that will ultimately allow sUAS’s to play a more positive role in our local community and our nation as a whole by increasing employment opportunities, heightening security measures and decreasing government expenditures by reducing the need for heavier manned aircraft, containing costly, combustible fuel- a potential public hazard in and of itself.3

3 I. Contact Information: Ruchek UAS Services c/o Scott M. Ruchek 6800 Desta Court Elk Grove, CA 95758 916-684-1062 ScottRuchek@yahoo.com

II. The Specific Sections of Title 14 of the Code of Federal Regulations From Which Ruchek UAS Services Requests Exemption are:

14 CFR 21; 14 C.F.R. 45.23(b); 14 CFR 61.113 (a) & (b); 14 C.F.R. 91, et seq.; 14 CFR 407 (a) (1); 14 CFR 409 (a) (2); and, 14 CFR 417 (a) & (b).

III. The Extent of relief Ruchek UAS Services Seeks and the Reason For Such Relief:

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:
1. The UAS's size, weight, speed, and operational capability 2. Operation of the UAS in close proximity to airports and populated areas 3. Operation of the UAS within visual line of sight of the operator
Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system."
The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 of the Act that includes sUASs, from the requirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702- 44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44701(f) See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203 (a) (1).4

4 Each of these items reflect in favor of an exemption for Ruchek UAS Services. My UAS’s utilize eight (8) or less rotating propellers for balance, control and stability. My UAS’s are equipped with the following via video and data telemetry:

1) Altimeter 2) Attitude indicator 3) Ground Speed indicator 4) Magnetic compass 5) Heading indicator 6) Vertical speed indicator 7) Course deviation indicator 8) Radio magnetic indicator 9) GPS location 10) Battery consumption and Battery Left with approximate time. 11) Loiter and circle mode. 12) Auto safety or RTL ( Return To Launch) 13) Auto landing technology.

I, Ruchek UAS Services, consider safety as foremost with each flight. My small unmanned aircraft are designed to hover in place, circle in a specific place or loiter via GPS. and can be operated in winds up to 30.4 knots (35mph). Built in safety systems include a GPS mode that allows my UAS to hover/circle in place or land when radio controls are released.

With different modes to choose from, I will fly with the modes safest to complete the flights for aerial inspection, monitoring and patrolling and have the ability to choose the safest, most reliable and stable mode to prevent accident and hazard. When pilot communication from the radio control is lost, UAS is designed slowly descend to point of takeoff and or to land at point of launch after ascending to a pre-set altitude to ensure the UAS will clear any obstacles that may be between the takeoff point and the current position of the UAS. This failsafe altitude will not be set more than 200ft and is determined before each flight.

I,Ruchek UAS Services,will not operate any sUAS's near airports, hospitals or police heliports, and do not operate near areas where general public is within fifty to one hundred (50-100) yards depending on location, conditions and weather. I am constantly on alert for any manned aircraft (police/medical helicopters, etc.) and prepared to land/abort immediately to the nearest and safest ground point should a manned aircraft approach my location or I suspect manned aircraft may approach near my location. My UAS’s are capable of vertical and horizontal operations, and is flown only within my line of sight, as the remote control pilot. My UAS's are also flown with a second operator who aids in watching for any obstacles, including manned aircraft, within the flight zone of the UAS. Utilizing battery power rather than combustible fuels, flights generallylast between ten (10) to twenty-five (25) minutes. Smart Mode include, position hold, selfleveling, altitude command, GPS, return home feature, and safety control to return home or land in the event of communication interruption between RC transmitter and UAS.5

5 Ruchek UAS Services will utilize a fresh fully charged battery with each flight as a safety precaution. I do not operate my UAS at or below manufacturer recommend minimum charge levels for operation; preferring to remain well within a safe operating range to insure adequate communication between radio control and UAS to eliminate potential for crash, loss of control or hazard. Reserve batteries are at hand with each exercise to insure replacement for sufficient safe level of operation. I do not believe in taking risk that may cause a crash, that could create hazard to the public/property/manned aircraft, and have no desire to lose an investment. Ruchek UAS Services has held a FAA Private Pilots license and have flown both fixed wing and helicopter and have stayed current with the FAA rules and regulations.

Ruchek UAS Services is extremely cautious when operating my sUAS's and will not “create a hazard to users of the national airspace system or the public.” 112 P.L. 95 § 333 (b). Given the small size and weight of my UAS, it falls well within Congress’s contemplated safety zone when it promulgated the Reform Act and the corresponding directive to integrate UAS's into the national airspace system.

IV. How Ruchek UAS Services Request Will Benefit the Public As A Whole: Aerial videography for geographical awareness, education, search and rescue, land management, structure inspections and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters. For small budget corporations, average homeowners and small independent businesses, the expense of such aerial videography is cost prohibitive. Manned aircraft pose a threat to the public through potential catastrophic crash. Each with combustible fuel that explodes and burns on impact. My, sUAS's pose no such threat since size and lack of combustible fuel alleviates any potential threat to the public. Congress has already proclaimed that it is in the public’s interest to integrate commercially flown UAS's into the national airspace system, hence the passing of the Reform Act. Granting, Ruchek UAS Services exemption request furthers the public interest through academic/visual awareness of the geographical benefits in and around the Greater Sacramento, California region. My small UAS is battery powered and creates no emissions that can harm the environment. The consequence of my sUAS crashing is far less than a full size helicopter or fixed wing aircraft; which are heavy, contain combustible fuel and can cause catastrophic devastation to the public. The public’s interest is furthered by minimizing ecological and crash threat by permitting aerial video/photo and other data captured through my battery operated ultra lightweight UAS's. Granting this exemption request to Ruchek UAS Services to immediately fly within national air space furthers economic growth, and substantially furthers the economic impact for the Greater Sacramento, California regionand surrounding community for companies looking to relocate or build, as well as individuals looking to relocate for career advancement through academic and geographical awareness. All of which serve as a stimulus to the community.

V. Reasons Why Ruchek UAS Services Exemption Will Not Adversely Affect Safety Or How The Exemption Will Provide a Level of Safety At Least Equal To Existing Rule:

Ruchek UAS Services exemption will not adversely affect safety. Quite the contrary, for the reasons stated permitting me, Ruchek UAS Services to log more flight time in FAA controlled airspace, with communication with the FAA, will allow me to contribute to the innovation and implementation of new and novel, as of yet undiscovered safety protocols for development in cooperation with the FAA. In addition, I only operate in reasonably safe environment that are6

6 strictly controlled, are away from power lines, elevated lights, airports and actively populated areas; I conduct extensive preflight inspections and protocol, during which safety carries primary importance; I always obtain all necessary permissions prior to operation; and, I have procedures in place to abort flights in the event of safety breaches or potential danger. My safety protocols provide a level of safety equal to or exceeding existing rules. It is important to note that absent the integration of commercial UAS into our national airspace system, helicopters are the primary means of aerial video and photography for community awareness in real estate, structured inspections, land management and search and rescue. While the safety record of such helicopters is remarkably astounding, there has been local incident involving loss of life as well as extensive property damage; it is far safer to operate a battery powered ultra lightweight UAS. First, the potential loss of life is diminished because UAS's carry no people on board and I only operates my UAS's in specific areas away from mass populations. Second, there is no fuel on board a UAS and thus the potential for fire or explosions is greatly diminished. Third, the small size and extreme maneuverability of my UAS's allow me to remotely pilot away from and avoid hazards quickly and safely. Lastly, given its small size and weight, even when close enough to capture amazing images, my UAS's need not be so close to the objects they are focused on through the technology and use of post editing software allowing pan and zoom. Accordingly, my UAS's have been experimentally operated for familiarization/competency and will continue to operate at and above current safety levels.

VI. A Summary The FAA May Publish in the Federal Register: 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR §91.203(a)(1). The size, weight and enclosed operational area of Ruchek UAS Services, UAS permits exemption from Part 21 because my UAS's meets (and exceeds) an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. Ruchek UAS Services, current and projected UAS's meet or exceed each of the elements.

14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable.

14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no on board pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a safety/flight manual delineating areas of where safety can be defined. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A, 10602, 10700 and 32827.

14 C.F.R. § 91.121 regarding altimeter settings is inapplicable insofar as my UAS utilizes electronic global positioning systems with a barometric sensor or controlled GPS “geofencing”7

7 14 C.F.R. § 91.203 (a) and (b) provides for the carrying of civil aircraft certifications and registrations. They are inapplicable for the same reasons described above. The equivalent level of safety will be achieved by maintaining any such required certifications and registrations by me, Ruchek UAS Services.

B. 14 C.F.R. § 45.23: Marking of The Aircraft. Applicable Codes of Federal Regulation require aircraft to be marked according to certain specifications. My UAS can be marked with the appropriate “N” number once this “N” number has been given.

C. 14 C.F.R. § 61.113: Private Pilot Privileges and Limitations: PIC. Pursuant to 14 C.F.R. §§ 61.113 (a) & (b), private pilots are limited to non-commercial operations. I, Ruchek UAS Services, the sUAS Pilot In Command (PIC) must possess at least a sport pilot certificate and a driver's license. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in which the PIC is rated on his/her pilot certificate as outlined in 14 C.F.R. § 61.

D. 14 C.F.R. 91.119: Minimum Safe Altitudes. 14 C.F.R. § 91.119 prescribes safe altitudes for the operation of civil aircraft. It allows helicopters to be operated at lower altitudes in certain conditions. My UAS will never operate at an altitude greater than the standard of 400 AGL. I, Ruchek UAS Services, will however operate my UAS in safe areas away from public and traffic, providing a level of safety at least equivalent to or below those in relation to minimum safe altitudes. Given the size, weight, maneuverability and speed of my UAS's, an equivalent or higher level of safety will be achieved.

E. 14 C.F.R. 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) & (b): Maintenance Inspections.1,2, Manual

The above-cited Regulations require, amongst other things, aircraft owners and operators to “have [the] 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 prescribed in part 43 of this chapter. . . .”These Regulations only apply to aircraft with an airworthiness certificate. They will not, therefore, apply to Ruchek UAS Services, UAS's. However, as a safety precaution I inspect my UAS before and after each flight.

A Summary The FAA May Publish in the Federal Register: A. 14 C.F.R. 21 and 14 C.F.R. 91: Airworthiness Certificates, Manuals and The Like. 14 C.F.R. 21, Subpart H, entitled Airworthiness Certificates, sets forth requirements for procurement of necessary airworthiness certificates in relation to FAR § 91.203(a)(1). The size, weight and enclosed operational area of my UAS permits exemption from Part 21 because Ruchek UAS Services UAS's meets an equivalent level of safety pursuant to Section 333 of the Reform Act. The FAA is authorized to exempt aircraft from the airworthiness certificate requirement under both the Act (49 U.S.C. § 44701 (f)) and Section 333 of the Reform Act. Both pieces of legislation permit the FAA to exempt UAS's from the airworthiness certificate requirement in consideration of the weight, size, speed, maneuverability and proximity to areas such as airports and dense populations. My UAS's meets or exceeds each of the elements. 14 C.F.R. 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. As no such certificate will be applicable in the form8

8 contemplated by the FARs, this Regulation is inapplicable. 14 C.F.R. § 91.9 (b) (2) requires an aircraft flight manual in the aircraft. As there are no pilots or passengers, and given the size of the UAS's, this Regulation is inapplicable. An equivalent level of safety will be achieved by maintaining a manual. The FAA has previously issued exemptions to this regulation in Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, maintenance program that involves regular software updates and curative measures for any damaged hardware. Therefore, an equivalent level of safety will be achieved.

In summary, Ruchek UAS Services seeks an exemption from the following Regulations:14 C.F.R. 21, subpart H; 14 C.F.R. 45.23(b); 14 C.F.R. §§ 61.113 (a) & (b); 14 C.F.R. §91.7 (a); 14 C.F.R. § 91.9 (b)(2); 14 C.F.R. § 91.103(b); 14 C.F.R. § 91.109; 14 C.F.R. §91.119; 14 C.F.R. § 91.121; 14 C.F.R. § 91.151(a); 14 C.F.R. §§ 91.203(a) and (b); 14 C.F.R. § 91.405 (a); 14 C.F.R. § 91.407 (a)(1); 14 C.F.R. § 91.409 (a)(2); 14 C.F.R. § 91.409 (a ) (2); and, 14 C.F.R. §§ 91.417 (a) & (b) to commercially operate Ruchek UAS Services small unmanned vehicle/lightweight unmanned aircraft vehicle in:  Search and Rescue  Education  Utility-power transmission system(s) patrolling and inspection  Pipeline monitoring, patrolling and inspection  Construction site monitoring, inspection and patrolling  Commercial building monitoring and inspections  Residential building/real estate inspections  Hydro-electric dam structure monitoring, patrolling and inspection  Wind turbines monitoring, patrolling and inspection  Cell Tower inspection and monitoring  Underground infrastructure monitoring, patrolling and inspection  Agricultural monitoring, patrolling and inspection  Bridge construction/maintenance patrolling and inspection  Aerial surveying/mapping  Public Entity Support Operations  Indoor and outdoor filmmaking, cinematography, and videography  Forestry and wildlife monitoring  Underground infrastructure monitoring and inspection and similar types of operations, both public and private and to develop economic platforms for the aforementioned to enhance the experience of those seeking to relocate, rebuild, reevaluate and to find in the Greater Sacramento, California Region.

F. Additional FAA Required Operating Conditions and Limitations
When not covered elsewhere in the Operations Manual, the following conditions and limitations apply: 1. The UA must weigh less than 55 pounds (25kg), including energy source(s) and equipment 2. The UA may not be flown at a speed exceeding a ground speed of 85 knots.9

9 3. Flights must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operator's manual. All altitudes reported to ATC must be in feet AGL.
4. The UAS 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 state driver’s license.

5. All operations must utilize a visual observer (VO). 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. 6. If a discrepancy exists between these limitations and any procedure outlined elsewhere in this operations manual, the conditions and limitations herein take precedence and
must be followed. 7. Prior to each flight, the PIC must inspect the UAS to ensure 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, if utilized, must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records. 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 in accordance with the operator's manual. The PIC who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. 9. The operator must follow the manufacturer's UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be established and identified in the operator's manual. At a minimum, the following must be included in the operator's manual:
a. Actuators / Servos
b. Transmission (single rotor)
c. Power plant (motors)
d. Propellers
e. Electronic speed controller
f. Batteries10

10 g. Mechanical dynamic components (single rotor)

h. Remote command and control
i. Ground control station (if used)
j. Any other components as determined by the operator
10. The Pilot in Command (PIC) must possess at least a sport pilot certificate and at least a current state driver’s license. 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/her pilot
certificate. 11. Prior to operations conducted 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), a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least ten hours logged as a UAS pilot with a similar UAS type (single blade or multi-rotor). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience-building flights can also be conducted under this grant of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considerednon-participants, and the PIC must operate the UAS with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 12. Prior to operations conducted 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), a minimum of five hours as UAS pilot operating the make and model of UAS to be utilized for operations under the exemption and three take-offs and three landings in the preceding 90 days. Training, proficiency, experience-building, and take-off and landing currency flights can be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience-building, and take-offand landing currency flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UAS with appropriate distance from non-participants in accordance with 14 CFR § 91.119.

13. Prior to any flight operations authorized by this grant of exemption, the PIC and visual observer (VO) must have successfully completed a qualification process, as outlined in the operator’s manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated at the sole discretion of the11

11 operator. A record of completion of this qualification process must be documented and made available to the Administrator upon request.

14. Prior to any flight operations authorized by this grant of exemption, a flight demonstration administered by an operator-approved and -qualified pilot must be successfully completed and documented. This documentation must be available for review upon request by the Administrator. Because the knowledge and airmanship test qualifications have been developed by the operator, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval of company designated examiners, the petitioner will conduct these tests in accordance with the operator’s manual.

15. The UAS may not be operated directly over any person, except authorized and consenting production personnel, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency.

16. Regarding the distance from participating persons, the operator’s manual has safety mitigations for authorized and consenting production personnel. At all times, those persons must be essential to operations. Because these procedures are specific to participating persons, no further FSDO or Aviation Safety Inspector (ASI) approval is necessary for reductions to the distances specified in the petitioner’s manuals.

17. Regarding distance from non-participating persons, the operator must ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the filming production. This provision may be reduced to no less than 200 feet if it would not adversely affect safety and the Administrator has approved it. For example, an equivalent level of safety may be determined by an aviation safety inspector’s evaluation of the filming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect non-participating persons (observers, the public, news media, etc.) from debris in the event of an accident. This is also consistent with the same FAA Order 8900.1, V3, C8, S1. 18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the security perimeter and land or be recovered in accordance with the operator’s manual.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the security perimeter and land or be recovered in accordance with the operator’s manual.12

12 19. The UAS must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the operator’s manual. 20. Each UAS operation must be completed within 30 minutes flight time or with 25%
battery power remaining, whichever occurs first.
21. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under this 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.

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

23. The operator must develop procedures to document and maintain a record of the UAS maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the UAS. These procedures must be added to the operator’s manual.

24. Each UAS operated under this exemption must comply with all manufacturer Safety

Bulletins.
25. The operator must develop UAS technician qualification criteria. These criteria must be added to the operator’s manual.

26. The preflight inspection section in the operator’s manual must be amended to include the following requirement: The preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operator’s manual.

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.13

13 28. The UAS must remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).

29. 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.

30. The UAS cannot be operated by the PIC from any moving device or vehicle.
31. The UAS 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. 32. The UAS may not operate in Class B, C, or D airspace without written approval from the FAA. The UAS may not operate within 5 miles of the geographic center of a non-towered airport 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. 33. Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the Federal Aviation Administration’s (FAA) 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. Further flight operations may not be conducted until the incident, accident, or transgression is reviewed by AFS-80 and authorization to resume operations is provided.

Respectfully submitted,

Ruchek UAS Services c/o Scott M. Ruchek 6800 Desta Court Elk Grove, CA 95758

916-684-1343 ScottRuchek@yahoo.com14

14 Appendix A



## List of Intended sUAS's

DJI Phantom 2 DJI Phantom 3 DJI Inspire 1 DJI Spreading Wings S800 DJI Spreading Wings S900 DJI Spreading Wings S1000 Freefly ALTA 3DRobotics X8 3D Robotics Iris 3D Robotics Solo SenseFly eBee Yuneec Q500 Typhoon Yuneec H920 Tornado

See attachment for manuals and specs for each sUAS indicated .