# Petition for Exemption

in Accordance with

14 CFR Part 11 and Section 333 of Public Law 112

- 95



# From

14 CFR

Part 21 , Subpart H; 61.113(a) and (b) 91.7(a); 91.103 (b) ; 91.119 (c) ; 91.121; 91.151(a)(1) ; 91.405(a) 91.407(a)(1) ; 91.409(a)(1) and (2) 91.417 (a) and (b)



# Submitted To

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



# by

1523 Kinnaird Ter NE Leesburg, VA 20176

March 2 , 2015

### Navigator CS, LLC

- Petition for Exemption 

## i 

# Table of Contents

Page

No.



## A. Introduction

.................................................................................................................. ... 1

A .1 Petitioner

..................................................................................................................................... 2

A .2 Intended Operations

................................................................................................................. 2

A .3 Small Unmanned Aircraft System (sUAS)

............................................................................... 2

A .4 Relief Sought

............................................................................................................................... 2



## B. Statutory Authority For Exemptions

...................................................... .................. 3

B.1 Hazards to Users of the NAS or the Public

.............................................................................. 4 B.2 Threat to National Security

........................................................................................................ 4

B.3 Airworthiness Certification

........................................................................................................ 5



## C

. Public Intere st

.................................................................................................................... 10



## D

. Regulations fr om Which Exemption is Sought

................................................... 10

D .1 14 CFR Part 21, Subpart H: Airworthiness Certificates

......................................................... 10

D .2 14 CFR 61.113(a) and (b): Private P ilot P rivi leges and L imitations: Pilot in C ommand 1 1

D .3 14 CFR 91.7(a): Civil Aircraft Airworthiness

............................................................................ 1 2

D .4 14 CFR 91.103(b): Pre

- Flight Action

......................................................................................... 1 2

D .5 14 CFR 91.119 (c) : Minimum Safe Altitu des

............................................................................ 1 3

D .6 14 CFR 91.121: Altimeter Settings

........................................................................................... 1 4

D

. 7 14 CFR 91.151(a)(1): Fuel Requirements for Flights in VFR Conditions

.............................. 1 5

D.8 14 CFR 91.405(a); 407(a)(1); 409(a)(1) a nd (a)(2); 417(a) and (b): Maintenance
Requirements

................................................................................................ ............................ 1 6



## E

. Regulations from Which Relief is Not Sought

..................................................... 1 7

E.1 14 CFR 45.23(b): Marking of the Aircraft

..................................................................... ......... 1 7

E

. 2 14 CFR 91.9 (b)(2): Civil A ircraft F light M anual, M arking, and P lacard R equirements 1 8

E

. 3 14 CFR 91.109: Flight Instruction

....................................................................................... 1 8

E .4 14 CFR 91.203(a) and (b): Carrying C ivil Aircraft C ertification an d R egistration 1 8



## F. Privacy

................................................................................................................................... 1 9



## G

. Summary for Publication in the Federal Registry

............................................. 1 9



## H

. Conclusion

............................................................................................................................ 20



## Attachment A: “ 

### Navigator CS, LLC’s P re

- Flight Checklist for Small Unmanned

Aircraft Systems (sUAS) Used in Commercial Operations ”



## Attachment B : “ Inspire 1 Operat ing Manual ”

### Navigator CS, LLC

- Petition for Exemption 

## 1



## A. INTRODUCTION

Pursuant to 14 C ode of Federal Regulations (14 C FR ) p art 11 and Section 333 of the F ederal Aviat ion

Administration (F AA ) Modernization and Reform Act of 2012 (Public Law 112

- 95), Navigator CS, LLC
(“Navigator”) hereby applies for an exemption from the Federal Aviation Regulations (“FARs”) listed in

table 1, to allow commercial operation of its small Unmanned Aircraft System (sUAS) Inspire 1

, manufactured by DJI Innovations, 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 of Public Law

112

- 95 or as l ater modified by Navigator under the approval of the FAA subsequent to future

amendments

.

This petition uses as guide s prior petitions for exemptions and their corresponding FAA rulings

, as well

as the FAA’s Notice of Proposed Rule Making (NPRM) Docket N o.: FAA

- 2015

- 0150

, Notice No. 15

- 01

, published on February 15, 2015. O n this NPRM, the FAA propos es to add a new part 107 to Title 14 Code

of Federal Regulations (14 CFR) to allow for routine civil operation of small UAS in the national air space

( NAS ) and to provide safety rules for those operations. Because the proposed part 107 regulation is not
final, and mindful that the final regulation might need to be redacted to address public comments,

Navigator is proposing actions that will allow its sUAS operat ions to achieve an equivalent level of safety

or that will meet the intent of (1) the airworthiness provisions of 14 CFR part 21; (2) airman certification

provisions of 14 CFR part 61; and operating limitations of 14 CFR part 91 , all of which will be repla ced by

14 CFR part 107.

The most onerous requirement imposed to date by the FAA as a condition for exemption from current

manned aircraft regulations, involves the requirement that the sUAS be operated by a Pilot

- In

Command (PIC) holding a private pilot c ertificat e and a third

- class airman medical certification. T he

knowledge currently necessary to obtain a private pilot certificate does not equip the certificate holder

with the tools necessary to safely operate a sUAS . Therefore, t he PIC must demonstrate that s/he is able

to safely operate the sUAS in a manner consistent with how the sUAS will be operated under the given

exemption, including evasive and emergency maneuvers, and maintaining appropriate distances from

people, vessels, vehicles, and structure s.

The proposed part 107 replaces the PIC certification requirement with the requirement that the sUAS be

operated by an operator holding an “ U nmanned A ircraft O perator C ertificate W

ith a S mall UAS R ating”

(see proposed 14 CFR 107.13 (a)). To o btain this certificate, the individual must be at least 17 years of

age; demonstrate English language proficiency (read, write, speak and understand English ); and pass an

initial aeronautical knowledge test in addition to demonstrating competency operating the sUA S

. Navigator will comply with the operator requirements in place at the time the FAA grants this petition.

In the following sections, Navigator discusses the actions that it proposes to take to ensure that its sUAS

operations do not create a hazard to the users of the NAS or the public, or pose a threat to national

security. Navigator also discusses how its proposed sUAS operations will be of benefit to the public.

### Navigator CS, LLC

- Petition for Exemption 

## 2

A. 1 Petitioner

The name and address of the petitioner is:

Navigator CS, LLC

1523 K innaird Ter NE Leesburg, VA 20176

Point of Contact: Gla dys M. Miller, M.S., M.B.A.

Sr. Project Engineer

Ph one No. : 703

- 568

- 7780

Email: gmiller@navigatorcs.com

Navigator is a properly verified s ervice disabled veteran

- owned small business performing engineering

and management consulting services in support of the construction, real estate, property management,

and information security industries. Navigator is the operator of the Inspire 1 , a sUAS equipped to

conduct aerial filming and photography.



## A.2 Intended Operations

This exemption w ill allow Navigator to use its sUAS Inspire 1 to safely, efficiently, and economically

obtain aerial imaging in support of engineering surveys of construction s ites , existing buildings and

facilities, and other sites, for the purpose of monitoring and ensuring site safety, proper material usage,

quality of workmanship and/ or to inspect the integrity of buildings and/or structures, including but not

limited to br idges, dams and others.



## A.3 Small Unmanned Aircraft System (sUAS)

The Inspire 1 sUAS manufactured by DJI Innovations consists of a lightweight (6.5 lbs. ) battery operated

quadcopter measuring 17.2 x 17.8 x 11.9 in. , a tablet

- based ground control station and/or RC Controller,

and associated communications equipment. The rotorcraft is a multirotor helicopter that is lifted and

propelled by four rotors. It carries an onboard geo

- referenced gimbaled camera that allows it to obtain

photography and videography.

Under normal conditions, the Inspire 1 operates at a speed of no more than 22 meters per second (50

mph; 43 knots ) and has the capability to hover and move in the vertical and horizontal plane

simultaneously. The battery is a lithium polymer LiPo 6S high voltage battery. The maximum flight

time is 18 minutes. The complete specifications for the Inspire 1 are contained in the “ Inspire 1

Operating Handbo o k” contained in Attachment B

.



## A.4 Relief Sought

Table 1 lists the regulations from which Navigator is seeking relief. Each of these is discussed in

detail in Section D, “Regulations for Which Exemptions is Sought,” along with Navigator’s proposed

actions to provide an equivalent level of safety or to meet the intent of the regulation.

### Navigator CS, LLC

- Petition for Exemption 

## 3 Table 1: Regulation s f rom W hich Navigator is Seeking R elief



## 14 CFR PART REGULATION DESCRIPTION

PART 21 AIRWORTHINESS CERTIFICATION

21, SUBPART H CERTIFICATION PROCEDURES FOR PRODUCTS AND PARTS,

AIRWORTHINESS CERTIFICATES

PART 61 CERTIFICATION: PILOTS, LIGHT INSTRUCTORS , AND GROUND INSTRUCTORS 61.113( a ) and ( b ) PRIVATE PILOT PRIVILEGES AND LIMITATIONS; PILOT IN COMMAND

PART 91 GENERAL OPERATING AND FLIGHT RULES 91.7( a ) CIVIL AIRCRAFT AIRWORTHINESS

91.103 (b) PRE

- FLIGHT ACTION

91.119 (c) MINIMUM SAFE ALTITUDES

91.121 ALTIMETER SETTINGS 91.151( a ) (1) FUEL REQUIREMENTS FOR FLIGHTS IN VFR CONDITIONS 91.405( a ) MAINTENANCE REQUIRED 91.407( a )(1) OPERATION AFTER MAINTENANCE 91.409( a )( 1 ) and ( 2) INSPECTIONS 91.417( a ) and (b) MAINTENANCE RECORDS REQUIRED

Table 2 lists regulations for which numerous petitioners have sought relief, but from which Navigator is

not seeking relief either because (1) they are not applicable to Navigator’s planned operations

, or (2)

bec ause the FAA has determined that relief is not necessary. To ensure that the FAA does not consider

this an oversight on the part of Navigator, Section E of this petition discusses each of the regulations in

Table 2, the reason why Navigator is not seeking relief, and actions that Navigator proposes to take to

en sure that the intent of the regulation is met, or that the sUAS operations provide an equivalent level

of safety.



### Table 2: Regulations f rom Which Navigator is NOT Seeking Relief



## 14 CFR PART SUMMARY OF REGULATION

PART 91 GENERAL OPERATING AND FLIGHT RUL ES 91.203(a) and (b) CARRYING CIVIL AIRCRAFT CERTIFICATION AND REGISTRATION 91.9(b)(2) CIVIL AIRCRAFT FLIGHT MANUAL IN THE AIRCRAFT 91.9(c) / 45.23(b) MARKING OF THE AIRCRAFT 91.109(a) FLIGHT INSTRUCTION



## B. STATUTORY AUTHORITY FOR EXEMPTIONS

The Federal Aviation Act expressly grants the FAA authority to issue exemptions. This statutory
authority includes exempting civil aircraft, as the term is defined under §40101 of the Act, including

sUAS, 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

### Navigator CS, LLC

- Petition for Exemption 

## 4

subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if the Administrator

finds the exemption to be in the public interest. 49 USC 44701(f)

. See also 49 USC §4471 l(a); 49

USC 44704; 14 CFR 91.203(a)(l).

In order to determine whether certain sUAS may operate safely in the NAS pursuant to section 333 of

Public Law 112

- 95, the Secretary must find that the operation of the UAS would not: (1) create a hazard

to users of the NAS or the public; or (2) pose a threat to national security. The Secretary must also

determine whether small UAS operations pose a safety risk sufficient to require airworthiness

cert ification.

Section 333(c) of Public Law 112

- 95 further states that i f the Secretary determines that a sUAS "may
operate safely in the national airspace system, the Secretary shall establish requirements for the safe
operation of such aircraft in the nat ional airspace system."



## B.1 Hazard to Users of the NAS or the Public

Section 333 of Public Law 112

- 95 requires the Secretary to determine whether the operation of the

s UAS would create a hazard to users of the NAS or the public. The t wo primary safety concerns associated with sUAS operations are: (1) the ability to “see and avoid” other aircraft with no pilot on

board; and (2) the operator losing positive control of the s UA aircraft. Navigator will mitigate these

concerns by adhering to the provisions listed in Table 3 , which are in line with proposed regulation 14

CFR part 107

.

The light weight of the Inspire 1 , coupled with the provisions listed in Table 3, significantly reduce t he

risk posed by Navigator’s proposed sUAS operations when compared wi th other categories of aircraft

that weigh more, fly higher, and are faster . Therefore, Navigator’s sUAS operations would not create a

hazard to u sers of the NAS or to the public.



## B.2 Threat to National Security

Section 333 of Public Law 112

- 95 also requ ires the Secretary to determine whether the operation of the

sUAS would pose a threat to national security. Under proposed 14 CFR part 107, these operations would

be subject to specific requirements, such as being able to operate only during daylight and o nly within

visual line of sight of the operator and, if applicable, a visual observer. The s UA would also have to be

registered with the FAA and to display its FAA

- issued registration marking prominently on the aircraft.

In addition, the operator of the sUA will be required to obtain a FAA

- issued “ U nmanned A ircraft

O perator C

ertificate W

ith a S mall UAS R ating. ” The process for obtaining this certificate will include the

same TSA

- review procedures that are currently used under 49 U S C 46111 to screen out airman

certificate applicants posing a security risk. These provisions , coupled with those contained in Table 3,

which Navigator will follow for all sUAS commercial operations, will ensure that Navigator’s sUAS

operations will not pose a threat to national security.

### Navigator CS, LLC

- Petition for Exemption 

## 5

B.3 Airworthiness Certification

S ection 333(b)(2) of Public Law 112

- 95 requires the Secretary to determine whether small UAS

operations pose a safety risk sufficient to require airworthiness certification. In previous exempt ions, as

well as in the preamble of the FAA’s Notice of Proposed Rule Making (NPRM) [Docket No.: FAA

- 2015

- 0150; Notice No. 15

- 01] published on February 15, 2015 , t he Secretary has determined that

airworthiness certification should not be required for sUAS due to their low

- risk operational

characteristics. In addition, the provisions listed in Table 3 and the pre

- flight checks that will be

performed (see Attachment A, “Navigator CS, LLC’s Pre

- Flight Checklist for Small Unmanned Aircraft

System (sUAS) Used in Commercial Operations” ) significantly reduce the risk associated with sUAS

operations.

In the above referenced NPRM, t he FAA emphasizes that the operator of the sUAS will not need to
determine design conformity or reliability probabilities when evaluati ng the airworthiness of the s UAS.

Instead, the operator w ill need to make a determination of whether the sUAS is in a safe condition

during flight operations and ground operations conducted for the purpose of flight. During pre

- flight and

post

- flight inspe ctions, the s UAS operator should conduct a simple visual inspection to look for simple

items such as dents, corrosion, misalignment, loose wires, binding controls, loose fasteners, and

excessive wear. This simple but not all

- inclusive list will identify mo st problems that could impact the

airworthiness and reliability of the aircraft.

Another inspection method unique to sUAS that would be governed by proposed rule 107 will be a

check of the control link. This check can be accomplished by using the control station to verify proper

flight control deflection prior to flight. The check can also be used to ensure the flight controls deflect

freely, without binding. Like the aforementioned inspection items, this too is a simple visual inspection

that should not r equire specialized training, and is included in “Navigator CS, LLC’s Pre

- Flight Checklist
for Small Unmanned Aircraft Systems (sUAS) Used in Commercial Operations” in Attachment A.

Because (1) th e proposed airworthiness provisions discussed above would su fficiently ensure that the

s UAS is in a condition for safe operation ; and (2) the provisions listed in Table 3 and the “Navigator CS,

LLC’s Pre

- Flight Checklist for Small Unmanned Aircraft Systems (sUAS) Used in Commercial Operations”

contained in Attachme nt A of this petition w ould ensure that the risk posed by small unmanned aircraft

is significantly smaller than the public risk posed by other groups of aircraft, pursuant to section

333(b)(2) of Public Law 112

- 95, airworthiness certification would be unne cessary for the sUAS.

### Navigator CS, LLC

- Petition for Exemption 

## 6 Table 3: Navigator’s Provisions to Mitigate Safety and Security Risks

Navigator’s Provisions to Mitigate Safety and Security Ris k s Applicable 14 CFR Regulations 1

For

Manned
Aircraft Proposed for

sUA S

General Provisions:

 The ma ximum gross weight of the sUA will be 6.5 lbs. This is below the 55

- lb limit in the definition of small unmanned

aircraft contained in P ublic Law 112

- 95, sec. 331(6)

.

 The airspeed of the SUA will not exceed 43 knots (50 mph). This is half the FAA proposed maximum airspeed of 87 knots.

 The sUAS will not be operated unless it is in condition for safe operation, as determined by Navigator’s preflight checks
and regu lar maintenance procedures

.

 The flight of the sUA will be discontinue d if conditions develop suc h that continuing the flight would pose a hazard to other aircraft, people, or property

.

 The sUA will h ave enough power to operate for its intended operational time and an additional four minutes

. S ee Section D.7 of this petition for Navigator ’ s reasoning on this matter. 91.7 (b) 14 CFR 107:

51(a)
15(a)

15 ( b)

49 (a)(4)

sUA Registration and Markings Provisions :

 The sUA will be registered with the FAA.

 The registration number will be displayed on the aircraft in as large a manner as practicable. The location of the display will be as prescribed for the type of aircraft. 45.29(f ) 14 CFR 107: 13(b)
13(c)

sUAS Maintenance Provisions:

 The operator will maintain the sUAS in a condition for safe operation by performing the manufacturer’s recommended

maintenance at manufacturer

- recommended regular intervals. 14 CFR 107: 21(a)

Operator and Visual Observer (VO) Provisions:

 The sUAS will be operated by a pilot

- in

- command (PIC ) holding a pilot private certificate.

 As soon as the process to obtain the “Unmanned Aircraft Operator Certificate with a Small UAS Rating ” is established

and operational, Navigator will use a holder of this certificate for the operation of its sUAS.

 Navigator will use a VO for its sUAS operations. The VO will not be allowed to operate the sUA. The operator will ensure

that the VO is able to see the sUA as specified in part 107 .31 and 37

 The operator and VO will only participate in the op erat ion of one sUAS at a time

.

 When operating the sUAS, the operator will refrain from careless or reckless behavior that could endanger the life or property of other. T his includes not dropping objects as to c reate a hazard to persons or property.

 The operator and VO will comply with the FAA alcohol and drug use prohibitions

. 91. 1 3 & 1 5

91.17 14 CFR 107:

13 (a)

33

35

23

27

1 While Navigator has made an attempt to reference relevant existing and proposed regulations pertaining to hazards to users of the NAS and the Public and threats to national security that apply to sUAS operations, the references identified on this Table are not all inclusive.

### Navigator CS, LLC

- Petition for Exemption 

## 7 Navigator’s Provisions to Mitigate Safety and Security Ris k s Applicable 14 CFR Regulations 1

For

Manned
Aircraft Proposed for

sUA S

 An i ndiv idual with a physical or mental condition that could interfere with the safe operation of the sUAS will not be allowed to function as operator or VO

. I n the even t that the operator or the VO have reason to believe that the physical

or mental condition of self or other might interfere wi th the safe operation of the sUAS, s/ he will immediately n oti fy t he
Project Manager for appropriate action

.

 T he operator and VO will scan the airspace where the s UA is operating for potential collision hazard s and will maintain awareness of the position of the s UA through direct visual observation.

 The operator and VO will maintain effective communication with each other at all times.

 The operator and VO will maintain V isual Line of Sight (V LOS ) of the sUA through the duration of the flight, with human vision that is unaided by any device other than corrective lenses

.

 The operator or VO’s vision of the sUA will be sufficient to allow them to know the sUA’s location; determine the sUA’s
attitude, altitude, and direction; observe the sUA for other traffic or hazards; and determine that the sUA does not endanger the life or property of another. 61.53(b ) 17

33 (d )

33 (a )

31 & 37 (a ) (1)
33(a )

31

31

Pre

- flight Inspections , Assessments, and Checks :

 T he operator will i nspect the sUAS to ensure that it is in a condition for safe operation. Th is includes perf orming the

manufacturer

- recommended preflight inspection and/ or performing an on

- the

- ground test of the s UAS to determine whether safety

- critical systems and components are working properly.

 T he o perator will ensure that all links between the control stati on and the sUA are working properly. In the event that a control link is not functioning properly, flight will not commence until the problem is resolved.

 The operator will become familiar with the confined area of operation by assessing the operating environment and risks

to person s and property in the immediate vicinity both on the surface and in the air. A s part of this pre

- flight assessment, the operator will consider conditions that could pose a hazard to the operation of the sUAS, as well as conditions in which the operation of the sUAS could pose a hazard to other aircraft or p ersons or property on the
ground. Special consideration will be given to :

 (1) local weather conditions;

 (2) local airspace and any flight restrictions;

 (3) the location of persons and property on the ground;

 (4) overhead wires and power transmission cables, and

 ( 5 ) any other ground or air hazards.

 The op erator will compare the GPS altitude read

- out with the launch site altitude to ensure proper readings.

 The operator will ensure that the sUAS will pose no undue hazard to other aircraft, people or p r operty in the event of loss of control of the aircraft for any reason. 1 4 CFR 107:

2 1(b)

49 (a) (3)

49(a)(1)

19 (b)

### Navigator CS, LLC

- Petition for Exemption 

## 8 Navigator’s Provisions to Mitigate Safety and Security Ris k s Applicable 14 CFR Regulations 1

For

Manned
Aircraft Proposed for

sUA S

 I f the operation takes place in a residential area, the operator will ask everyone in the area of operation to remain

ins ide their homes while the operation is conducted.

 If the operation takes place in an area where other air traffic could pose a hazard, the operator will advise local air

traffic control as to the location of his or her area of operation and add extra vis ual observers to the operation so
that they can notify the operator if other aircraft are approaching the area of operation.

Please refer to Attachment A, “ Navigator CS LLC’s Pre

- Flight Checklist for Small Unmanned Aircraft Systems (sUAS) Used in

Commer cial Operations ” for additional details

. Provisions to C o nfine A rea of O perations ( to mitigate risks associated with loss

- of

- positive

- control ) :

 The operator will always be able to see the sUA unaided, except for corrective lenses, as appropriate

.

 The sUA will not be operated from a moving aircraft or land

- borne vehicle

.

 The sU A will operate at an altitude not to exceed 500 ft above ground level (AGL)

.

 The sUA operations will take place in Class G airspace. Operations in Class A airspace will not be allowed. Operations in
Class B, C, D, and E airspace, as well as in prohibited or restricted areas

, require permission from the ATC having jurisdiction over the airspace and/or from the using or controlling agency.

 Navigator shall fully cooperate with the sUAS manufacture r to upgrade sUA S operating software, as appropr iate, to incorporate exclusion or no

- fly zones. 14 CFR 107: 33 (c )

25 51 (b)

41 , 45, and 47

“See

- and

- Avoid” and V isibility P rovisions:

 V LOS w ill be maintained throughout the flight

.

 Operations will be conducted during daylight, between the hours of official sunr ise and sunset

.

 Minimum flight visibility from the control station will be three statute miles (5 km)

.

 The sUA will be no less than 500 ft below clouds and 2000 ft horizontally from clouds

. 91.113(b) 14 CFR 107:

31

29 51 (c )
51 (d)

Mid

- Air C ollision A voidance P rovisions:

 The UAS operator will always initiate avoidance maneuvers to avoid collision with any other user of the NAS.

 The sUAS will not operate so close to any other aircraft as to create a collision hazard

. 91.111 (a) 14 CFR 107: 37 (a)(2) 37 (b)

Other P rovisions to M itigate the R isk P osed by L oss

- of

- P ositive

- C ontrol:

 Prior to flight, the operator will ensure that all links between the control station and the aircraf t are working properly

and that the battery is fully charged

.

 The sUA will not be operated over people not directly involved in the operation

 Prior to the flight, the operator will ensure that all persons directly involved in the operation receive a briefing that

in c lud es: (1) operating conditions; (2) emergency procedures; (3) contingency procedures; (4) roles and responsibilities; and (5) potential hazards

.

 The operator will ensure that the sUAS will not pose undue hazard to other aircraft, people, or property in the event of 4 CFR 107:

49 (a) (3)

39

49 (a) (2)

19 (b )

### Navigator CS, LLC

- Petition for Exemption 

## 9 Navigator’s Provisions to Mitigate Safety and Security Ris k s Applicable 14 CFR Regulations 1

For

Manned
Aircraft Proposed for

sUA S

loss of control of the aircraft

.

 The Inspire 1 ’s operating software includes a “Failsafe Return to Home” feature which will automatically fly the aircraft back to the point of origination of the flight if the remote controller signal is lost for more than three seconds

. Demonstration of Compliance Provisions:

 Upon FAA’s request, Navigator will make available to the FAA any document, record, or report required to be kept
regarding the operation and maintenan ce of the sUA S . This includes the operator’s “ Unmanned Aircraft Operator Certificate with a sUAS Ratin g ” certificate, and the Certificate of Registration for the sUAS being operated.

 Navigator, its o perator and/or VO, will allow the FAA to make any test or inspection of the sUAS, the operator and/or
the VO, to determine compliance with applicable regulations.

 Within 10 days of occurrence, Navigator will report to the FAA any sUAS operation that results in injury to a person or damage to property other than the sUA. 14 CFR 107: 7(a)

7(b)

9

### Navigator CS, LLC

- Petition for Exemption 

## 10



## C. PUBLIC INTEREST

This application for exemption is expressly submitted to fulfill Congress' goal in passing Section 333(a)
through (c) of Public Law 112

- 95

. This law directs the Secretary to consider whether certain

u n m a n n e d a i r c r a f t s y s t e m s m ay operate safely in the NAS before completion of the rulemaking required under Section 33 3 of the Law . By granting this exemption, the FAA will fulfill Congress's intent of allowing sUAS to operate with significant safety precautions i n low risk

environments.

The use of sUAS to obtain aerial imaging in support of engineering surveys of construction sites, existing

buildings and facilities, and other sites, for the purpose of monitoring and ensuring site safety, proper material usage, q uality of workmanship and/ or to inspect the integrity of buildings and/or structures,

including but not limited to bridges, dams and others, can significantly reduce the risk to workers

arising from falls while inspecting, surveying, or monitoring site pr ogress. Small UAS can take

video and photos, and collect data on high and hard

- to

- get

- to areas , such as building exteriors,

towers, and roofs that otherwise would require worker inspection. Falls are the leading source of

workplace fatality and injury on c onstruction site s 2 and reducing the possibility of falls by using

sUAS for site imaging could significantly reduce the safety risk for workers performing many

such inspection s, ultimately save workers ’ lives.

Additionally, sUAS could replace the use of h elicopters and small aircraft to monitor sites and take
site/project progress photographs

. Navigator’s selected sUAS weighs 6 . 5 l b s a n d c a r r i e s no explosive materials or flammable liquid fuels on board, as opposed to much larger,

conventionally powered sma ll aircraft. The use of sUAS over helicopters presents a substantial increase

in safety for workers and the public.

W hen used for aerial imaging and data collection over construction and other sites, the Inspire 1’s

rechargeable Lithium Polymer battery ( LiPo 6S) has a reduced environmental impact over fossil fuel

burned to operate much heavier small aircrafts.



## D

. REGULATIONS FR OM WHICH EXEMPTION IS S OUGHT

The regulations from which Navigator is seeking relief are listed in Table 1 of this petition. T his Section

discusses each of these regulations, the reasons why Navigator is seeking relief, and Navigator’s

provisions to assure an equivalent level of safety, as applicable.



## D .1 14 CFR Part 21, Subpart H: Airworthiness Certificates

Subpart H, Airwor thiness Certificates , establishes the procedural requirements for the issuance of

airworthiness certificates as required by FAR 91.203 (a)(1). Given the size and limited operating area

associated with the aircraft to be utilized by Navigator , an exemption from Part 21 Subpart H meets the

2 “ Commonly Used Statistics", Occupational Safety and Health Administration. Available at: https://www.osha.gov/

oshstats/ commonstats.html

### Navigator CS, LLC

- Petition for Exemption 

## 11

requirements of an equivalent level of safety under Part 11 and Section 333 of Public Law 112

- 95.

The Federal Aviation Act (49 U.S.C.44701 (f)) and Section 333 of Public Law 112

- 95 authorize the FAA to

exempt aircraft fr om the requirement for an airworthiness certificate, upon consideration of the

sUAS’ size, weight, speed, operational capability, and proximity to airports and populated areas

.

As discussed in Section B.3 of this petition, the FAA has determined in pre vious exemptions that

airworthiness certification should not be required for sUAS due to their low

- risk operational

characteristics. The provisions listed in Table 3 and on “Navigator CS, LLC’s Pre

- Flight Checklist for Small

Unmanned Aircraft Systems (sU AS) Used in Commercial Operations

, “ contained in Attachment A of this

petition significantly reduce the risk associated with Navigator’s sUAS operations. During preflight and

post flight inspections, Navigator will seek to identify problems that could im pact the airworthiness and

reliability of the sUA S . In addition, before each flight, the control link will be checked to ensure proper
flight control. These combined efforts will ensure that Navigator’s sUAS is in a condition for safe

operation.

An anal ysis of these provisions demonstrates that Navigator’s s UAS operated without an airworthiness

certificate, in the restricted environment

, and under the provisions in Table 3 and “Navigator CS, LLC’s

Pre

- Flight Checklist for Small Unmanned Aircraft Systems (sUAS) Used in Commercial Operations”

contained in Attachment A

, will be as safe as, or safer than, conventional aircraft operating with an

airworthiness certificate without the restrictions and conditions proposed.

Navigator’s Inspire 1 weighs less than 10 lbs.

, carries neither a pilot nor passenger, carries no explosive

materials or flammable liquid fuels, and operates exclusively within a secured area as set out in Table 3

of this petition. Like other civil aircraft, operations under this exemption will be tightly controlled and

monitored by the operator, and will be i n compliance with local public safety requirements, to provide

security for the area of operation as is currently done on active construction sites. These safety

enhancements, which alread y apply to civil aircraft operated in connection with construction sites,

provide a greater degree of safety to the public and property owners than conventional operations

conducted with airworthiness certificates issued under 14 CFR Part 21, Sub part H.

The FAA has previously granted exemptions from this regulation, some examples of which may be found

in Exemption Nos. 11062, 11067, 11080

, 111 12

, 11114, and 111 38

.



## D.2 14 CFR 61.113(a) and (b): Private P ilot P rivileges and L imitations: Pilot

in C ommand

Section 61.113(a) and (b) prescribe that

( 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 compensati on 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

### Navigator CS, LLC

- Petition for Exemption 

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

Unlike a conventional aircraft

, which is operated by an onboard pilot, Navigator’s sUA will not carry

a pilot, passengers, or any other life form on board . T he sUA will be remotely controlled a nd, as

shown on the provisions contained in Table 3 and on “Navigator CS, LLC’s Pre

- Flight Checklist
for Small Unmanned Aircraft Systems (sUAS) Used in Commercial Operations” contained in

Attachment A , the area of operation will be controlled and restrict ed, and all flights will be

planned and coordinated in advance

. The se provisions are consistent with the requirements

proposed by the FAA in NPRM Docket No. FAA

- 2015

- 0150, Notice No. 15

- 01, dated February 15,

2015, and s ignificantly reduce the risk of N avigator’s sUA operations compared with t he level of

risk posed by the commercial operations governed by Part 61.

To date, t he FAA has granted petitions for exemption similar to this one, and has authorized

sUAS to be operated by a PIC with a private pil ot certificate and third

- class airman medical

certification . The PIC has been required to demonstrate his/her ability to operate the sUAS. In
the above referenced NPRM, the FAA proposed that sUA be operated by an operator holding

an “ U nmanned Aircraft Oper ator Certificate with a sUAS R ating

. ” Navigator will comply with the

requirements current at the time this petition is granted , which will provide an equivalent level of

safety as that achieved by 14 CFR 61.113(a) and (b).

The FAA has issued the followin g exemptions to this regulation as shown in E xemption Nos. 11062,

11065, 11067, 11110, 11109, 11136 and 11138.



## D.3 14 CFR 91.7(a): Civil A ircraft A irworthiness

Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an air worthy

condition. As there will be no airworthiness certificate issued for the aircraft, should this

exemption be granted, there will be no FAA regulatory standard for determining

airworthiness. T he size and operational characteristics of the aircraft

, th e provisions outli ned in

Table 3 of this petition r elated to preflight inspections, checks, assessments, and maintenance

, and on “

Navigator CS, LLC’s Pre

- Flight Checklist for Small Unmanned Aircraft Systems (sUAS)

Used in Commercial Operations” contained i n Attachment A of this petition , which incorporate
the FAA’s proposed requirements for sUA S

, w ill ensure that the Inspire 1 is in a condition for

flight. Therefore, an equivalent level of safety will be provided.

The FAA has granted exemptions from this regulation in several instances, including Exemption Nos.

11080, 11109, 11136, 11138, 11150, 11153, 11157, and 11159

.



## D.4 14 CFR 91.103 (b) : Preflight Action

Section 91.103 prescribes that the aircraft’s pilot in command shall, before beginning a flight, become

familiar with all available information concerning that flight. This information must include :

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance

### Navigator CS, LLC

- Petition for Exemption 

## 13 information:

(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civil aircraft other than those specified in paragraph (b)(1) of thi s section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of
airport elevation and runway slope, aircraft gross weight, and wind and temperature.

Navigator seeks relief from this regulation b ecause the type of information and actions required to

ensure the safe operation of a sUA are different from those called for in 14 CFR 91.103 (b). The

Provisions contained in Table 3, particularly those pertaining to preflight inspections, assessments, a nd

checks, and completion of “Navigator CS, LLC’s Pre

- Flight Checklist for Small Unmanned Aircraft Systems
(sUAS) Used in Commercial Operations” shown in Appendix A of this petition

, will ensure an equivalent

level of safety as that provided for conventio nal aircraft governed by 14 CFR 91.103(b).



## D.5 14 CFR 91.119 (c) : Minimum Safe Altitudes

Section 91.119 prescribes that, except when necessary for takeoff or landing, no person may operate
an aircraft below the following altitudes:

(a) Anywhere. An a ltitude allowing, if a power unit fails, an emergency landing without undue hazard to
persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open

- air assembly of persons, an alti tude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, t he aircraft may not be operated closer than 500 feet to any
person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without
hazard to persons or property on the surface

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or paragraph (c)
of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

Section 91.119(d) allows helicopters to be operated at less than the minimum prescribed altitudes

, provid ed the person operating the helicopter complies with any route or altitudes prescribed for

helicopters by the FAA. This petition of exemption is for a quadcopter that flies similarly to a helicopter,

with vertical take

- off and vertical landing, which will typically operate at altitudes of 200 feet above

ground level ( AGL ) or less . Therefore, an exemption will be needed to allow such operations.

As stated in Table 3, Navigator intends to conduct its sUAS operations in secure, confined areas that are

not co ngested. To this effect, the only portion of this regulation fr om which Navigator seeks relief is

119(c), which sets the minimum flying altitude to 500 f eet AGL. This is the maximum allowable flying

### Navigator CS, LLC

- Petition for Exemption 

## 14

altitude proposed by the FAA in NPRM Docket No. FAA

- 2015

- 0150, Notice No. 15

- 01, published on February 15, 2015.

Navigator’s sUA will not operate over any person that is not directly involved in the operation of the

sUAS unless these persons are protected by a structure. Further, prior to its sUA S commercia l

operations, Navigator will ensure that:

(1) All persons directly involved in the sUA S operation receive a briefing that includes operating

conditions, emergency procedures, contingency procedures, roles and responsi bilities, and

potential hazards;

(2) A ll persons not essential to flight operations (nonparticipating persons) remain at least 500 ft.

away from the area of operations unless they are protected by barriers or structures that can

sufficiently protect non

- participating persons from debris in t he event of an accident. The

operator will ensure that nonparticipating persons remain under or within such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of

the s UA, flight operations will ce ase immediately or the operator will move the aircraft to a safe

distance , whichever is safer

.

(3) In the event that operations need to be conducted closer than 500 ft. from vessels, vehicles

and/or structures , Navigator will first obtain permission from the owner/controller , and the

operator will make a s afety assessment of the risk of operating closer to those objects.

The size, weight, and speed of the Inspire 1

, combined with the provisions listed above and in Table 3

and Attachment A of this petitio n will ensure the safety of Navigator’s sUAS operations and will provide

an equivalent level of safety as that intended for conventional aircraft governed by 14 CFR 91. 119,

which are he avier and carry flammable fuel.

Some of the exemptions where t he FAA h as granted relief from this regulation include Exemption Nos.

4063, 11062, 11063, 11066, 11067, 11080, 11109, 11110, 11112, 1113 6, and 11138

.



## D.6 14 CFR 91.121: Altimeter Settings

Section 91.121 requires each person operating an aircraft to maintain cru ising altitude by reference

to an altimeter that is set " ...to the elevation of the departure airport or an appropriate altimeter

setting available before departure."

Navigator requests relief from this regulation because its sUAS does not have a barome tric

altimeter but a G lobal Positioning System (G PS ) altitude read

- out whose altitude information is

generated by GPS equipment installed onboard the aircraft

. Prior to each flight, t he GPS read

- out
will be verified by the operator by comparing it to the l aunch site altitude , thus setting the zero altitude

initiation point. To actively monitor the flight path, the sUAS operator will have access to altitude

information via a radio communications telemetry data link which downlinks from the sUA to the

operat or. These provisions, coup led with Navigator’s intent to operate its sUA within VLOS below 5 00

### Navigator CS, LLC

- Petition for Exemption 

## 15

feet AGL , will ensure the safety of Navigator’s sUAS operations, and will provide an equivalent level of

safety as that intended by the provisions of 14 CFR 91. 121 for conventional aircraft.

The FAA has granted relief from this regulation , as shown in Exemption Nos. 1113 6 , 1113 8

, 1115 0

, 1115 3 and 11159

.



## D.7 14 CFR 91.151(a)(1): Fuel R equirements for F light in VFR C onditions

Section 91.151(a) prescribes that no person may begin a flight in an airplane under visual flight rules

(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

(1) Durin g the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.

As indicated in Table 3, Navigator will conduct its sUAS operations in daylight; for this reason, the fuel

requirement for night operations c overed under 151(a)(2) is not applicable, and Navigator is only

seeking relief from 151(a)(1). This relief is required because the battery that power s the Inspire 1

provides approximately 18 minutes of powered flight , thus making it unfeasible to meet this 30

- minute

fuel reserve requirement

.

An equivalent level of safety will be provided by commanding the aircraft to return to the ground

control station when the battery has 20% of power remaining . It should be noted that in its proposed

regulations for s UAS, the FAA is requiring t hat the sUAS have enough power for its intended operational

flight plus 5 minutes. Given the short (18 minute) flight duration allowed for the Inspire 1 by its battery

power, Navigator ’s 20% battery power provision will allow 14 minutes of flight time and leave 4 minutes

of battery reserve. While this does not meet the 5 minutes in the proposed regulation we feel it

provides a significant safety margin, complies with the current requirement and provides a reasonable

flight time without adversely affecting the safety of the operations. Navigator’s proposed provision has

been found acceptable by the FAA on previous exemptions, including Exemption No. 11109.

Navigator’s provision to return the aircraft to the ground control sta tion when the battery reaches 20%

of power can be easily carried out because w hen in flight, the remaining battery power of the Inspire 1

is shown live on the o perator’s display , letting the o perator know the remaining flight time. Built

- in

algorithms calc ulate the distance of the aircraft and the estimated time to return to the ground control

station, which allows the operator to know when it’s time to fly back. Th ese features, combined with the

above flight

- duration provision, the confined nature of the o perating area, and the size, weight, speed

, and construction material of the Inspire 1 will ensure the safety of Navigator’s sUA S operations.

To date, the FAA has granted relief from this regulation to sUA S for daytime, VFR conditions . Examples

of these exemptions include Exemption Nos. 2689F, 5745, 8811, 10159, 10650, 10673, 10808, 11112,

1113 6 and 1113 8

.

### Navigator CS, LLC

- Petition for Exemption 

## 16

D.8 14 CFR 91.405 (a); 407(a)(1); 409(a)(1) and (2); 417(a) and (b):

Maintenance Requirements

Section 91.405(a) prescribes that e ach owner or ope rator 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 prescribed
in part 43 [Maintena nce, Preventive Maintenance, Rebuilding, and Alteration] of this chapte r

.

Section 91.407(a)(1) prescribes that

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance,

r ebuilding, or alteration unless

(1) It has b een approved for return to service by a person authorized under §43.7 of this chapter;

Section 91.409 (a)( 1 ) and (2) prescribe that:

(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.

Section 91.417(a) and (b) prescribe that

(a) Each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the main tenance, preventive maintenance, and alteration and records of the 100

- hour,
annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records

must i nclude

(i) A description (or reference to data acceptable to the Administrator) of the work performed;

and (ii) The date of completion of the work performed; and (iii) The signature and certificate number of the person appro ving 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, engin e, propeller, rotor, and
appliance. (iii) The time since last overhaul of all items installed on the aircraft that are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the l ast 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) for each major alteration to the airframe and

### Navigator CS, LLC

- Petition for Exemption 

## 17 current ly 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 repeate d 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 t o a registered owner or operator under § 43.11 shall be retained until the defects are repaired and the aircraft is approved for return to service.

Given that these section and Part 43 apply only to aircraft with an airworthiness certificate, these

sectio ns will not apply to Navigator ’s sUA S

. However, Navigator’s sUA S operator will ensure

that the Inspire 1 is in proper working condition prior to initiating flight operations (see

Provisions in Table 3 and “Navigator CS, LLC’s Pre

- Flight Checklist for Smal l Unmanned

Aircraft Systems (sUAS) Used in Commercial Operations” contained in Attachment A of this

petition ). Regular preventive m aintenance will be accomplished i n a c c o r d a n c e w i t h t h e

manufacturer’s operating manual . The date and type of preventive and c orrective maintenance will

be documented on the sUA log, which will be made available to FAA personnel upon request.

The above provisions, combined with the Inspire 1’s size and weight and the confined area where it

will be operated for short periods of time, will achieve an equivalent or level of safety as that

intended by th ese regulation s for conventional aircraft.

The FAA has granted similar exemptions from these regulations, as shown in Exemption Nos.

11080

, 11109

, 11136

, 11138

, 11150, 11153

, 1115 7 and , 1115 9.



## E. R EGULATIONS FROM WHICH RELIEF IS NOT SOUGHT

As mentioned earlier, previous petitioners have sought relief from other regulations which the FAA has

determine d are not necessary or applicable. To ensure that the FAA does not consider this an oversight

on the part of Navigator, those regulations are discussed next, along with the reason why Navigator is

not seeking relief, and the actions that Navigator proposes to take to ensure that the intent of the

regulation is met, or that its sUAS op erations provide an equivalent level of safety.



## E.1 14 C FR 45.23(b): Marking of the Aircraft

This regulation prescribes that:

(b) When marks include only the Roman capital letter “N” and the registration number is displayed on limited,

restricted or li ght

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not
less than 2 inches nor more than 6 inches high, t he words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable

.
As stated by the FAA on previous rulings (see Exemption No. 11109) , this regulation applies only to

aircraft with an experimental certificate under 14 CFR Pa rt 21.191, which is not the case here. For this

reason, Navigator is not seeking relief from this regulation

. Navigator’s sUAS will be identified by serial

### Navigator CS, LLC

- Petition for Exemption 

## 18

number, it will be registered with the FAA in accordance with 14 CFR part 47, and will have identif ication

(N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as

practicable.



## E.2 14 CFR 91.9 (b)(2): Civil A ircraft F light M anual, M arking, and P lacard

R equirements

Section 91.9(b)(2) prescribes, in pertinent part, that no person may operate a US

- registered civil aircraft

unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual,

approved manual material, markings, and placards, or any combination thereof

.

Due to its small si ze and configuration

, the sUA has no ability or place to carry a flight manual

on the aircraft ; therefore, an exemption is required. On previous exemptions, however, t he FAA

has stated that based on th e FAA’s memorandum titled "Interpretation regarding whe ther certain

required documents may be kept at an UA's control station" dated August 8, 2014 , relief is not

necessary

. Navigator will achieve an equivalent level of safety by keeping the flight manual at the

ground control point where the PIC/ o perator fly ing the sUAS will have immediate access to it.



## E.3 14 CFR 91.109: Flight Instruction

Section 91.10 9 provides that no person may operate a civil aircraft (except a manned free balloon)

that is being used for flight instruction

, unless that aircraft has f ully functioning dual controls. By

design, sUAS and remotely piloted aircraft do not have fully functional dual controls. Flight control

is accomplished through the use of a control box that communicates with the aircraft via radio

communications. The FAA has previously approved exemptions for aircraft without fully functional

dual controls. See Exemption Nos.5778K and 9862A.

In Exemption No. 11109, the FAA ruled that this regulation does not apply if the operator does not

intend to conduct training that requires dual controls. Because Navigator does not intend to

conduct training that requires dual controls, this regulation does not apply and Navigator is,

therefore, not seeking relief from it.



## E.4 14 CFR 91.203(a) and (b): Carrying C ivil A ircraft C erti fication and

R egistration

The regulation provides in part:

(a) Except as provided in § 91.715, no person may operate a civil aircraft unless it has within it the following:

(1) An appropriate and current airworthiness certificate. . .

.

(b) No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin
or cockpit entrance so that it is legible to passengers or crew.

The s UAS fully loaded weighs no more than 10 lbs. and is operated without an onboard pilot.

### Navigator CS, LLC

- Petition for Exemption 

## 19

Therefore

, there is no ability or place to carry certification and registration documents or to

display them on the sUAS. An equivalent level of safety will be achi eved by keeping these

documents at the ground flight control point where the PIC/ o perator will have immediate access

to the se documents

.

T he FAA has already addressed this matter on the memorandum titled "Interpretation regarding

whether certain required documents may be kept at an UA's control station" dated August 8, 2014. For

this reason, Navigator is not seeking relief from this regulation. Prior to the above referenced

memorandum, the FAA ha d issued numerous exemptions to this regulation (see Exempt ion Nos.

9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700 )

.



## F

. P RIVACY

All of Navigator’s sUA flights will occur over private or controlled access property with the prior

consent and knowledge of the property owner or the authority having jurisdict ion. Images taken

will be of individuals who have consented to being filmed or otherwise have agreed to be in the

area where aerial imagery will take place.



## G

. SUMMARY FOR PUBLICATION IN THE FEDERAL REGISTER

Pursuant to 14 CFR 11, Navigator provides the following summary for publication in the Federal Register, should the FAA determine that publication is needed.

***********************************************************************************************************************

In accordance with 14 CFR Part 11 and Section 333 of Public Law 112

- 95 (the 2012 Reform Act) Navigator CS, LLC seeks relief from the following rules:

14 CFR Part 21, Subpart H; 14 CFR 61.113 (a) and (b); 14 CFR 91.7(a); 14 CFR 91.103(b); 14 CFR 91.119(c); 14 CFR 91.121; 14 CFR 91.151(a)(1); 14 CFR 91.405(a); 14 CFR 91.407(a)(1); 14 CFR 91.409 (a)(1) and (2); 14 CFR 91.417 (a) and (b);

Approval of this petition will allow petitioner to safely, efficiently, and economically operate commercially a small unmanned aircraft (s UA) weighing less than 10 lbs, to obtain aerial imaging in support of engineering surveys

of construction sites, existing buildings and facilities, and other sites, for the purpose of monitoring and ensuring site safety, proper material usage, quality of w orkmanship and/ or to inspect the integrity of buildings and/or structures, including but not limited to bridges, dams and others.

Conventional operations in this industry using rotorcraft o r fixed

- wing aircraft present the risks associated

with vehicles that weigh several thousand pounds and carry large amounts of fuel. Such aircraft must fly to and from the survey or inspection site and operate at low altitudes. In contrast, the sUA weigh s less

than 10 lbs. , is powered by batteries , is transported (not f lown) to the designated site, and carries no

passengers or crew. These features eliminate virtually all risk s posed by manned aircraft flights for this

purpose.

The operation of a sUA weighing less than 10 pounds provides an equivalent level of safety an d thus supports the grant of the exemptions requested herein, including exempting the applicant from the requirements of part 21 and allowing commercial operations. These light sUAS operate a slow speed, close to the ground, and in a sterile environment. A s a result, they are safer than conventional aerial survey and inspection operations conducted with fixed

- wing aircraft o r helicopters.

***********************************************************************************************************************

### Navigator CS, LLC

- Petition for Exemption 

## 20



## H

. CONCLUSION

As detailed in this document and attach ments, the requested exemption will permit the commercial operation of sUAS under controlled conditions in airspace that is limited, predetermined and accessed

controlled, and would provide safety en hancements to the already best practices and safety protocols followed by Navigator in the conduct of surveys and inspections at construction and other sites. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportati on's (the FAA Administrator's) responsibilities to "...establish requirements for the safe operation of such aircraft systems in the national airspace system."

T he small size and light weight of the Inspire 1

, its operating capabilities, the restricted a nd sterile

environment within which Navigator will operate it, the provisions in Table 3 that Navigator is
committed to maintain, and “Navigator CS, LLC’s Pre

- Flight Checklist for Small Unmanned Aircraft Systems (sUAS) Used in Commercial Operations” conta ined in Attachment A, which will be used by
Navigator for all commercial operations, Navigator’s proposed sUAS operations fall within the zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption,

allow co mmercial operations of sUAS to commence immediately. In addition, as discussed in Section B.2 of this petition, approval of this petition presents no threat to national security

.

Given the clear direction in Section 333 of Public Law 112

- 95 , the autho rity contained in the Federal

Aviation Act, as amended

, the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, FAA’s g ran ting of the requested
exemptions is in the public in terest. Accordingly, Navigator respectfully requests that the FAA grant the
requested exemption s without delay.