1 P.O. Box 1663 ● Idaho Falls, Idaho ● 83403

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## U.S. Department of Transportation

Docket Management System

1200 New Jersey Ave., SE

Washington, DC 20590

RE: Exemption Request under Section 333 of the FAA Modernization and

Reform Act and 14 C.F.R. Part 11

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, Snake River Search, Inc. (a 501(c)3 non

- profit

corporation) , seeks an exemption from the Federal Aviation Regulations (FARs)

listed and discussed in Appendix A in order to allow for the operation of small

Unmanned Aircraft System s (UAS) under the conditions and limitations s et forth

in this application for Petition.

Snake River Search requests the exemption to permit the operation of small

Unmanned Aircraft Systems to support search operations for missing persons. We

believe that the use of UAS will enhance both the success of the search and the

safety of the searchers in the wilderness areas that we typically operate in.

The requested exemption would authorize Snake River Search to perform

operations with the UAS that will benefit the public as follows:

Acquire real

- ti me aerial views of search areas that are difficult or dangerous

to access on the ground. Real

- time information can be used to direct ground

teams to areas of interest. Water searches in river sections that are too rough

for divers or boats, or on remo te waters where the UAS can be packed in.

Acquire digital imagery which can be analyzed using computer systems,

either on site, or utilizing crowd analysis via the web.

The use of the UAS will significantly reduce the risk to the searchers while

increasing the likely

- hood of a positive outcome.2 P.O. Box 1663 ● Idaho Falls, Idaho ● 83403

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## Statement of Background and Public Benefit

Snake River Search, Inc. (a 501(c)3 non

- profit corporation) traces its origins to the

Bonneville County Jeep Patrol founded in 195 8 to support wilderness searches for

missing persons. Currently Snake River Search has six K9 search teams, man

trackers, a Fusion Center with advanced mapping and analysis capabilities , as well

as communications capabilities. The UAS Lead is a retired US AF Navigator and

Private Pilot who has extensive experience with airspace management and remote

sensor operations. Other members include pilots, a PhD in Engineering and

Applied Sciences

, and many engineers. All members have passed a background

check and most currently do or have held DOE and/or DOD security clearances

. All members are volunteers and none receive monetary gain.

Operations will be purely for the benefit of the public and no payment will be

requested for services provided.

The use of the UAS will significantly improve our ability to conduct searches for

missing persons in the remote wilderness areas within our operational arena.

All imagery collected will be utilized solely for the purpose of search operations

and training, and none wi ll be released without a thorough review.

The physical risk to the public is minimal and is easily off

- set by the benefits of

quickly locating missing persons and the reduced risk to the search personnel.3 P.O. Box 1663 ● Idaho Falls, Idaho ● 83403

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## Qualification for Approval under Section 333 of The Reform Act

The UAS operations proposed in this application of petition for exemptions qualify

for expedited approval under Section 333 of the Reform Act. This petition outlines

how each statutory criteria a nd other potentially relevant factors are satisfied.

The proposed operations would permit the use of small UAS within the Nation al

Airspace (NAS) under controlled operational conditions.

Snake River Search is proposing to operate Quad

- Copter rotorcraft that will weigh

less than 5lbs in flight condition. Operations would occur under normal VFR

conditions and at speeds less than 30mph. (the UAS that will be used is the DJI

Phantom II Vision

- Plus.) Operations will be conducted by qualified

o perator/observer teams to maximize operational success and safety. For both

operational and safety reasons the UAS will operate at less than 400’ AGL and

within visual sight. The systems will include fail

- safe fly

- home capability and

software preventing operations in controlled/restricted airspace wi ll be utilized.

Pertaining to the UAS :

UAS will weigh typically less than 3 lbs., and always less than 10 lbs.

UAS will operate at a maximum speed of no greater than 30mph

.

UAS will operate below 400ft AGL.

UAS shall not be operated within 5 miles of an airport without prior

approval of, and establishing a line of communication for the duration of the

flight operations with the controlling authority of that airspace/airport.

UAS will be operated within vi sual line of sight (VLOS) of the PIC and

VO(s).4 P.O. Box 1663 ● Idaho Falls, Idaho ● 83403

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## UAS will follow pre

- determined flight paths over the mission area

conducted via automated navigational flight software.

UAS will be operated under visibility and cloud clearance requirements

equivalent to Visual Flight Rules (VFR).

UAS will be equipped with an autopilot system. UAS will utilize GPS

navigation, systematic pre

- flight checks, and failover safety mechanisms

including return

- to

- home (RTH), auto

- land, loiter and flight abort saf ety

features.

Pertaining to Pilots, Visual Observer(s) and Ground Control Station crew :

Minimum crew for each operation will consist of the UAS Pilot in

Command (PIC), Visual Observer ( VO) and/or Ground Control Station

(GCS) crew.

The UAS pilot will be considered the Pilot in Command (PIC) and be

responsible for conducting safe flight operations.

The UAS PIC will have an FAA aviation certification.

VO and GCS personnel will complete training equivalent to a Private Pilots

Grou nd school prior to operational deployment in addition to training on the

hardware and software being utilized, and mission oriented operational

requirements.

PIC, VO(s) and/or GCS crew will have communications established in

advance of any flight oper ations.

The UAS PIC will be trained in advance for the safe operation of the UAS

to be operated. This will include operation of the UAS both in normal and5 P.O. Box 1663 ● Idaho Falls, Idaho ● 83403

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## emergency procedures and will include familiarization with the flight

manual (or similar) fu rnished by the UAS manufacturer. Training will

include basic flight maneuvers, navigational awareness, emergency

procedures, loss of uplink, loss of downlink, loss of GPS and safe flight

operations in relation to persons, property and applicable airspace.

T raining will include a minimum of 100 takeoff/landing cycles, 25 hours of

total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS

pilot with a simil ar UAS type. Prior to operational employment the PIC

must have accumulate d and logged a minimum of 5 hours as UAS PIC

operating the make and model of UAS to be utilized as well as 10 takeoffs

and landings in the pr e ceding 90 days. Specific training will include normal

and emergency modes of operation and will include familia rization with the

operation manual published by the UAS manufacturer. Training will also

include types of maneuvers to be performed during operations including safe

operation in relation to persons, property and applicable airspace.

UAS PIC will establish a working relationship with a representative at the

l ocal Flight Standards district Office (FSDO) with which to annually review

safety procedures and other operations to further enhance safety.6 P.O. Box 1663 ● Idaho Falls, Idaho ● 83403

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## Pertaining to Flight Operations :

Safety is paramount and r isk assessment evaluation s will be conducted for

safe site operations and flight conditions before each mission.

A briefing will be conducted in regard to the planned UAS flights prior to

operation at each new location. All personnel who will be performing duties

within the boundaries of the area of operation will be present for this

b riefing.

Prior to a UAS flight, an area of operation will be established. This area of

operation will include a defined late ral and vertical area, where the UAS will

operate. Safety procedures will be established for persons, property and

applicable airspace within the area of operation.

Flights will be operated in Class G airspace whenever possible. If operation

in other airspace is required, the appropriate controlling authority will be

notified at least 24 hours prior to the operation and, if required, any

necessary permission obtained.

See and avoid: If at any time the operator see or hears another aircraft and it

appears that aircraft may come within one (1) mile of the UAS, or it is

questionable whether or not it will do so, the PIC shall immediately descend

the UAS and direct it on a heading toward the designated landing area, or an

alternate landing area if n ecessary, until the UAS has landed or it is

de termined the other aircraft has maintained a separation of one (1) mile.

The UAS shall operate from on

- site launch/landing locations directly next to

the PIC and GCS crew. Non

- essential flight operation personnel will be at an

appropriate distance away or a minimum of 5 0ft from the operation unless

barriers or structures are in place which may sufficiently protect observers or

other personnel in case of UAS emergency.7 P.O. Box 1663 ● Idaho Falls, Idaho ● 83403

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## Flight planning will include flight completion with at least 25% battery

power remaining as measured by the UAS or appropriate flight time

planning.

A Ground Control Station (GCS) will be connected by radio communication

to the UAS during the entire flight operation. Flight information relayed to

the PIC will include UAS GPS position, altitude, speed, compass

heading/bearing, aircraft angle of attack, flight time, battery power

remaining, and other telemetry information.

Written, and/or document ed oral permission from property owners or land

management agency will be obtained prior to an operation as required

.

In summary, it is the Applicant's belief that the size, weight, speed, operating

environment, and operating capabilities of each UAS will provide an "equivalent

level of safety" or better when operating for commercial and public interest as

outlined in Section 333 of the Reform Act. Applicant appreciates the time and

consideration given to this request for exemption to permit safe and l egal UAS

operations within the NAS.

Respectfully,

Snake River Search, Inc.

Attn: David J. Forker

Telephone: (208)589

- 0533

Email: DJFOR@SARDALE.COM

P.O. Box 1663, Idaho Falls, ID 83403

Attch: Glossary of Terminology

Appendix A

– Exemption Requests8 P.O. Box 1663 ● Idaho Falls, Idaho ● 83403

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## GLOSSARY OF TERMINOLOGY:

COA Certificate of Authorization

FAA Federal Aviation Administration

FLIR Forward Looking Infrared

GIS Geographic Information Systems

GPS Global Positioning System

GCS Ground Control Station

NAS National Airspace

NIR Near

- Infrared

NOTAM Notice to Airmen

PIC Pilot in Command

RS Remote Sensing

TIR Thermal Image Recorder

VFR Visual Flight Rules

VLOS Visual Line of Sight

VO Visual Observer

UAS Unmanned Aircraft System9 P.O. Box 1663 ● Idaho Falls, Idaho ● 83403

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# APPENDIX A

EXEMPTION IS REQUESTED FROM THE FOLLOWING

REGULATIONS:

Part 21 prescribes the procedural requirements for issuing and changing design approvals, productions

approvals, airworthiness certificates, and airworthiness approvals.

Exemption Requested Because: Should not apply to small UAS.

Section 45.23(b) prescri bes that when marks include only the Roman capital letter “N” and the

registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or

provisionally certificated aircraft, the operator must also display on that a ircraft near each entrance to

the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the

words “limited,” “restricted,” “light

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

Exemption Requested Becau se: Physically impossible to implement on a small UAS

Section 45.29(b)(iii) prescribes, in pertinent part, that marks at least 3 inches high may be displayed on

an aircraft for which the FAA has issued an experimental certificate under §21.191(d), § 21.191 (g), or §

21.191(i) of this chapter to operate as an exhibition aircraft, an amateur

- built aircraft, or a light

- sport

aircraft when the maximum cruising speed of the aircraft does not exceed 180 knots calibrated airspeed.

Exemption Requested Because: Phy sically impossible to implement on a small UAS

Section 91.9(b)(2) prohibits operation of U.S.

- registered civil aircraft unless there is available in the

aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings,

a nd placards, or any combination thereof. Exemption Requested Because: Physically impossible to

implement on a small UAS

Exemption Requested Because: Should not apply to small UAS.

Section 91.109(a) prescribes, in pertinent part, that no person may operate a civil aircraft (except a

manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning

dual controls.

Exemption Requested Because: Physically impossible to implement on a small UAS

Section 91.119 prescribes th at, except when necessary for takeoff or landing, no person may operate an

aircraft below the following altitudes:10 P.O. Box 1663 ● Idaho Falls, Idaho ● 83403

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(a) Anywhere. A t a n altitude allowing, if a power unit fails, an emergency landing without undue hazard

to persons or property on the surfa ce.

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

assembly of persons, an altitude 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, the aircraft may not be operated closer than 500 feet to any

person, vessel, vehicle, or structure.

(d) Helicopters, power ed 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 (c) of this

section, provided e ach person operating the helicopter complies with any routes or altitudes specifically

prescribed for helicopters by the FAA,

(2) A powered parachute or weight

- shift

- control aircraft may be operated at less than the minimums

prescribed in paragraph (c) of this section.

Exemption Requested Because: For operational and safety reasons the UAS needs to operate below 400’

AGL at all times.

Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude

by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate

altimeter setting available before departure.”

Exemption Requested Because: The UAS will utilize GPS for altitude control.

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

unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of

intended landing and, assuming normal cruising speed, during the day, to fly after that for at least 30

minutes

.

Exemption Requested Because: Flights will be within visual sight, will typically last less than 30 minutes,

and battery level will be monitored to ensure a safe UAS recovery.

Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has

within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration

certificate issued to its owner or, for oper ation within the United States, the second copy of the Aircraft

registration Application as provided for in § 47.31(c).

Exemption Requested Because: Physically impossible to implement on a small UAS11 P.O. Box 1663 ● Idaho Falls, Idaho ● 83403

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Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft unless the

airworthiness certificate 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.

Exemption Requested Because: Phy sically impossible to implement on a small UAS

Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have that aircraft

inspected as prescribed in subpart E of the same part and shall, between required inspections, except as

provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of

the chapter.

Exemption Requested Because: Inspections of small UAS will be limited to operational checks of the

hardware and software prior to each f light.

Section 91.407(a)(1) prohibits, in pertinent part, any person from operating an aircraft that has

undergone maintenance, preventive maintenance, rebuilding, or alteration unless it has been approved

for return to service by a person authorized under § 43.7 of the same chapter.

Exemption Requested Because: Small UAS do not present the same risks as manned aircraft and require

minimal maintenance. Alterations from manufacturer configuration will not be made.

Section 91.409(a)(2) prescribes, in pertin ent part, that no person may operate an aircraft unless, within

the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness

certificate in accordance with part 21 of this chapter.

Exemption Requested Because: A COA will be requested and maintained as directed/required.

Section 91.417(a) and (b) prescribes, in pertinent part, that

—

(a) Each registered owner or operator shall keep the following records for the periods specified in

paragraph (b) of this section:

(1) Recor ds of the maintenance, 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 ap pliance of an aircraft. The records must

include

— 4

(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 approving the aircraft for return to service.

(2) Records containing the following information:12 P.O. Box 1663 ● Idaho Falls, Idaho ● 83403

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(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, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled

on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last 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 comp liance, 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) of this chapter for each major alter ation to the airframe

and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated 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 retain ed and transferred with the

aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner or operator under5

Exemption Requested Because: These records would serve no purpose in enhancing the safe operation

of the small UAS

§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for

return to service.

Exemption Requested Because: These records would serve no purpose in enhancing the safe operation

of the small UAS

FAA Notice 8900.227, paragraph 16.c.(4), PIC Medical , states that the PIC must maintain, at a minimum,

a valid FAA second

- class medical certificate issued under 14 CFR part 67, Medical Standards and

Certification, or the FAA

- recognized equivalent.

Exemption Requested Because: The medical certificate is predicated on manned flight.13 P.O. Box 1663 ● Idaho Falls, Idaho ● 83403

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Paragraph 16.e.(1), Medical , states that all observers must have a valid FAA second

- class medical

certificate issued under part 67; an FAA

- recognized equivalent is an acceptable means of demonstrating

compliance with this requirement.

Exemption Requested Because: The medical certificate is predicated on manned flight.