Unmanned Systems, Inc

.

May 30 th, 2015 2709 Cyrano Street Henderson, NV 89044 Cell (406)471.3996

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

Dear sir or Madam, As you are aware, as of February 2012, with the passage of Public Law 112

-95, Unmanned Aircraft Systems (UAS) are considered aircraft, therefore their operation is subject to Title 14 of the Code of Federal Regulations (14 CFR) Parts 91 & 61. Due to the d esign of UAS and nature of their operations, operators are either unable to comply or in some cases it’s simply impractical to comply with certain regulatory requirements, resulting in , as in this case, the UAS operator requesting an exemption from the ru le. Unmanned systems Inc. (USI) hereby request exemptions from the following regulations for Its Sandstorm electric (E), turbine (T) and gas (G) models.
14 CFR § 61.113 (a) no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: flight is **only incidental** to that business or employment; USI is request ing an exemption from 61.113 (a) & (b) to allow U SI pilots to operate the Sandstorm UAS as PIC and holding only a private pilot certificate, for compensation or hire.14 CFR § 91.119

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely po pulated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. USI is request ing an exemption from 91.119 (c) to allow USI to operate the Sandstorm UAS below 500 feet Above Ground Level (AGL)
14 CFR § 91.121 : (a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as case may be, reference to an altimeter that is set, when operating USI is requesting an exemption from the altimeter setting requirements of 91.121
14 CFR § 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 of intended landing and, assumi ng normal cruising speed, (1) during the day, to fly after that for at least 30 minutes [emphasis added]. USI is requesting an exemption to the fuel / power reserves required by 14 CFR § 91.151 **The FARs** The Petitioner seeks exemption from the above mentioned FARs for the following

reasons; **14 CFR § 61.113(a) & (b)**  ; The Petitioner requests relief in order to facilitate the utilization of an experienced UAS pilot with the addition of a trained observer. All pre

-flight inspection, maintenance and flight logs will be saved and made available to the FAA and Secretary of Transportation (SoT) for review; with the purpose of safely integrating civil UAS operation in the National Airspace System. Currently Sandstorm Pilots have at least a private pilot Certific ate and second class medical.

**14 CFR § 91.119(c)**  As discussed in Exemption 11138 (DOUGLAS TRUDEAU), operations conducted closer than 500 feet to the ground may require that the UA be operated closer than 500 feet to essential persons, or objects that wo uld not be possible without additional relief. The Petitioner requests modification, waiver or exemption and clarification concerning the terms “congested areas” and “densely populated”. ThePetitioner requests waiver for this condition to allow reasonable and responsible operations in areas of

subdivisions and neighborhoods if required. The Petitioner will primarily operate the UAS between ground level and 400 feet. The UAS will be operated over designated properties with the owner’s consent and while main taining a safe distance from persons. The Petitioner will compile flight data from the logs. This data may assist the FAA in development of regulations for commercial operations in low

risk, controlled environments. **14 CFR § 91.121**  As discussed in Exemption 11138 (DOUGLAS TRUDEAU) is inapplicable since the UAS does not have an altimeter and instead utilizes electronic GPS with a barometric sensor for altitude information. It is reset to zero prior to flight. The safety pilot is a backup reference for altitud e as he is in line of sight of the UAV. **14 CFR § 91.151(a)**  As discussed in Exemption 11136 (ADVANCED AVIATION SOLUTIONS LLC) prior relief has been granted for manned aircraft to operate at less than the prescribed minimums, including Exemption Nos. 2689, 5745, and 10650. In addition, similar UAS specific relief has been granted an Exemption Nos. 8811, 10808, and 10673 for daytime, VFR conditions. The UAS provides battery power remaining in percent to the PIC. The batteries for the Sandstorm E model provide approximately 40 minutes of powered flight. The Sandstorm T and G models have approximately 4 hours of flight. Information provided in the operating documents discusses procedures regarding remaining battery power management. Those documents contain a con dition in which the PIC will initiate a landing procedure when battery remaining reaches a specified level. Given the limitations on proposed operations and the location of those proposed operations, The FAA found that a reduced minimum power reserve for flight in daytime VFR conditions was reasonable. **History /Public Interest**  Sandstorms E , T and G models have been used in USI ’ s companion trainer program for 4 years. It has had its experimental certifications for 4 years. It has had g reat success with N441N S keeping many UAS operators current . Sandstorm has now been approved by the government for Predator qualification t raining. We are now exploring opportunities in the commercial market. We would like to give the opportunity to all people wh o have an intere st in Flying UAS commercially

. I for one have seen its positive influences as I am bound to a wheelchair it has given me the opportunity to fly once again. The primary purpose of seeking this exemption is to obtain that capability to offer those services w hile remaining in compliance.

Respectfully submitted

Justin Sands