January 22, 2016

Stillwater UAS LLC

2619 Austin Court

Stillwater , OK 740 74

U.S. Department of Transportation Docket Operations West Building Ground Floor

Room W12

- 140 1200 New Jersey Avenue, SE., Washington, DC 20590

- 0001

RE: Exemption Reque st Section 333 of the FAA Reform Act of 2012 and Part 11 of the

Federal Aviation Regulations

Dear Sir or Madam; In accordance with the Public Guidance for Petitions for Exemption filed under Section
333, Stillwater UAS LLC requests exemption from the Fe deral Aviation Regulations to allow for commercial UAS operations of a DJI Phantom 3 Professional, DJI Inspire 1,

and Matrice 100 for the purpose of aerial photography, tower inspection, real estate marketing, surveying, agricultural mapping , search and re scue, UAS instruction and ground training, and other flight operations that could be performed safe r, quicker, and more cost effectively than with traditional manned aircraft.

Applicant:

Stillwater UAS LLC

2619 Austin Court Stillwater, OK 74074 mark@stillwateruas.com

508

- 560

- 5444

Attachments links to d ocuments and manuals for:

DJI phantom 3 professional http://www.dji.com/product/phantom

- 3/dow nload

DJI Inspire 1 http://www.dji.com/product/inspire

- 1/download

Matrice 100https://developer.dji.com/matrice

- 100/downloads

Regulations from which the exemption is requested: 14 CFR 21, Subpart H 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a) 14 CFR 91.7 (a) 14 CFR 91.9 (b)(2) 14 CFR 91.103 (b)(2)

14 CFR 91.109 14 CFR 91.119 (c)

14 CFR 91.121

14 CF R 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 91.407 (a)(l) 14 CFR 91.409 (a)(l) & (a)(2) 14 CFR 91.417 (a) & (b)

14 CFR 21, Subpart H

- In consideration of the size, weight, speed, and limited operat ing

area associated with this U AS and its operation, Stillwater UAS LLC request s relief from 14 CFR part 21, Subpart H, and any associated noise certification and testing requirements of part 36. The UAS will carry neither pilot, passenger, explosive materials or flammable liquids.

14 C FR 45.23 (b)

- Even though the UAS will have no airworthiness certificate, an exemption may be needed as the UAS will have no cabin, cockpit

, or pilot station on which the word "Experimental" can be placed. Given the size of the UAS, two

- inch lettering will be not be possible. The word "Experimental" will be placed on the fuselage
in compliance with § 45.29 (f). The equivalent level of safety will be provided by
having the UAS marked on its fuselage as required by § 45.29 (f) where the pilot,

observer and othe rs working with the UAS will see the identification of the UAS as "Experimental."

14 CFR 61.113 (a) & (b) & 14 CFR 61.133 (a)

- Since the UAS will not carry a pilot or

passengers
, Stillwater UAS LLC request s relief from these regulations. A licensed priva te /commercial pilot (VFR and IFR SEL ) will be the PIC and sole manipulator of the

controls . A visual observer or (VO) will be utilized and required to communicate verbally

with me at all times. The UAS will be limited to operations within visual distance o f both the PIC and VO. All UAS operations will take place in a controlled area. The risks

associated with the use of a UAS are far less than similar commercial aircraft operations.14 CFR 91.7 (a)

- Since the UAS will not carry a pilot or passengers there will be no airworthiness certificate issued for the aircraft, should this exemption be granted, no FAA regulatory standard exists for determining airworthiness. Given the size of the aircraft, maintenance, and use of safety checklist prior to each flight, an equivalent level of safety will be provided. All flights for each aircraft will be in accordance with the safety and

maintenance recommendations found in the attac hed manufacturers’ manuals

.

14 CFR 91.9 (b)(2)

- Given the size and configuration, the U AS has no ability to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry a flight manual. An equivalent level of safety will be maintained by keeping the flight manual at the ground station where the UAS pilot will have immediate access to it.

14 CFR 91.103 (b)(2)

- As no FAA approved flight manuals will be provided for the

aircraft listed, an exemption is needed. Alternate procedures including but not limited to reviewing airspace, weather conditions, c hecking flight battery requirements, checking takeoff and landing distances

, along with checklists found in the manufacturers’ manuals will be implemented. These actions will provide an equivalent or higher level of safety

.

14 CFR 91.109

- UAS and remotel y piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraft via radio communications. An equivalent level of safety will be achieved using the real time grou nd station data since the UAS will carry neither a pilot or

passengers.

14 CFR 91.119 (c)

- The UAS will never be operated at an altitude higher than 400 feet AGL. The UAS will operate in safe areas away from public and traffic and only with permission of the property and structure owners. The UAS will also be restricted by the flight controller to a maximum vertical height of 400 feet AGL, and 1500 feet horizontal. Given the size, weight, maneuverability and speed of the UAS, an equivalent or higher

level of safety will be achieved.

14 CFR 91.121

- As the UAS may not have a barometric altimeter, but instead a GPS barometric sensor for altitude information an exemption may be required. An equivalent

level of safety will be achieved using a ground station w hich links to a tele m etry data link. This will provide the pilot with live flight data monitoring, confirming the altitude of the launch site shown on the GPS altitude indicator prior to flight.

14 CFR 91.151 (a)

- The UAS has a limited range and will be limited to operations in a controlled environment. The battery power the UAS above provide approximately 2 2

minutes of flight time. The UAS is unable to meet the 30

- minute reserve requirement and therefore requires an exemption. An equivalent level of safe ty will be achieved by monitoring the battery through the ground station and landing with a minimum of 30 percent battery power remaining.

14 CFR 91.203 (a) & (b)

- Given the size a nd configuration, the UAS does not have theability to carry a flight manu al on the aircraft. There is no room, capacity, or pi lot on

board to store a flight manual. An equivalent level of safety will be maintained by keeping the flight manual at the ground station where the UAS pilot will have immediate

access to it. Given the following sections only apply to aircraft with an airworthiness certificate, these sections do not apply to this applicant. As a safety precaution, the operator will perform preflight inspections and ensure UAS is in working condition before initiating eac h flight:

14 CFR 91.405 (a) 14 CFR 91.407 (a)(1) 14 CFR 91.409 (a)(l) & (a)(2) 14 CFR 91.417 (a) & (b)

Equivalent Level of Safety

In addition to the safety standards mentioned above the UAS will adhere to the following

additional guidelines:

1. The U AS will not be operated within 5 miles of an airport unless prior contact to Air

Traffic Control has been established.

2 . Flights will not exceed the airspeed of 87 knots (100 mph) 3. Flights will be operated at or b elow an altitude of 400 fee t AGL. 4. The PIC and VO will communicate verbally at all times. 5. UAS operations will not be conducted during night , as defined in 14 CFR § 1.1. 6. All operations will be conducted under VMC

. 7. The UAS will land with a minimum 30 percent battery reser ve remaining. 8. The UAS will only be piloted within visual line of sight

. 9. The UAS will utilize an internal flight safety feature that will return to a preprogrammed position and land if communication with the remote control is lost. 10. Preflight inspections and protocol will be followed prior to all operations. 11. The UAS will abort flight in the event of unpredictable obstacles or emergencies. 12. Operated by the Applicant , a licensed private pilot.

Public Interest

I believe the use of a UA S to supplement manned aircraft w ill enhance safety and help

reduce the impact t o the environment compared to similar operations conducted with a manned aircraft carrying a flight crew and flammable fuel.

The inspections of cellular communication towers or similar structures will eliminate the risks associated with persons climbing these structures. The photographs and video s collected can provide engineers with valuable information as to the needed maintenance

of these structures for safety.

The use of a UAS in the real estate industry helps provide a higher level of marketing and

service for all parties involved . The UAS is able to provide a view which can capture theentire property in a single photo or short video clip. When compared to similar opera tions, utilizing a UAS poses much less of a safety concern for the general public with less fuel, time, noise and other resources.

The use of a UAS in search and rescue make it possible to place resources where they need to be quicker which can help save lives and property. A UAS can be deployed and provide a broader picture of conditions to help the incident commander make a more

informed decision.

Privacy

All flights will occur over private or controlled areas with the owner's consent. Any

person c aptured in a collected image will have consented prior to filming or otherwise have agreed to be in the area prior to the filming taking place. The right to privacy will always be respected and considered. In the case of search and rescue, the standard

ope rating procedure of the authority having jurisdiction will serve as rule in the case of emergencies when consent cannot be obtained from each individual.

Sincerely,

Stillwater UAS LLC Applicant /Operator