### Larsen 333 Petition

July 16, 2015 P a g e | 1 of 12 

## Erick F. Larsen

262 W. Linden Ave. # C Burbank, LA, Ca 91502
818

- 732

- 0330 ErickLarsen@Outlook.com July 16, 2015

U. S. Department of Transportation Docket Management System

1200 New Jersey Ave., SE Washington, DC 20590

Re: Erick F. Larsen’s Request (Petition) for Exemption from Certain Regulations per Section 333 of the FAA Reform Act and Part 11 of the Federal Aviation Regulations

Dear Sir or Madam:

Pursuant to Section 333 of t he FAA Modernization and Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Erick F. Larsen (Larsen, Petitioner, or Operator ) hereby applies for an exemption from the listed Federal Aviation Regulations (FARs ) to allow business use (commercial oper ation) of his Unoccupied (unmanned) Aerial System (UAS), 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.

I. INTRODUCTION

Petitioner, Erick F. Larse n, is a United States born citizen, with the following contact information, residing at:

262 W. Linden Ave. # C Burbank, Los Angeles Co, Ca 91502
818

- 732

- 0330 ErickLarsen@Outlook.com

Petitioner, Larsen, has been building and operating model aircraft for more than fifty (50)

years. Petitioner currently maintains a duly issued US Passport and a Driver ’s License issued by the California Department of Motor Vehicles (DMV)

. Moreover, as a former IT Airport Systems Program Manager upon behalf of Los Angeles World Airports (LAWA), the operator of the Los Angeles International Airport (LAX), Petitioner, Larsen, has been cleared (background checked) to work in all of the most secure and sterile areas within and on the surrounding airfield of the Tom Bradley International Terminal (TIBIT) of LAX including within all critical IT Data Rooms of LAWA and of the Federal Inspection Service Areas (FIS) of the US Customs and Border Protection (CBP) which is part of the US Depart ment of

### Larsen 333 Petition

July 16, 2015 P a g e | 2 of 12 Homeland Security (DHS). A copy of petitioner’s LAX/CBP/FIS badge is confidentially

attached.

In addition, Petitioner successfully underwent a distinct background investigation in October of 2013 by the State of California in order to become a Cov ered California Certified Enrollment Counselor (CEC) #1969, which is a matter of public record.

Small business is the backbone of America. Through years of UAS hobbyist experience, petitioner has developed numerous diverse prospective clients in need of s afe and lawful
commercial UAS aerial data collection (ADC ) services. A small UAS business operated by petitioner will provide new jobs and an increased level of safety to clients currently in need
of UAS ADC commercial services. Existing FAA UAS policy bar s Petitioner from providing UAS

ADC commercial services in the absence of the requested exemption.

Petitioner seeks to operate UAS to conduct aerial data collection (ADC) which includes any remote sensing and measuring by an instrument(s) aboard the Unoc cupied (Unmanned) Aircraft (UA). Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instrum ents aboard the UA.

In particular Petitioner seeks authorization to conduct commercial UAS remote ADC, mapping, surveying, photography, filming, demonstrations, training, surveying, measuring, and inspections of (or for):

1.) Construction, architectural , engineering, insurance, risk management, security, real estate, resort, golf, cemetery, entertainment, sports, utility, energy (oil, gas, solar, wind, & electric), hydro (water), transportation (port, rail, truck, & bus), mining, bridge,
telecommunicatio ns, agriculture (farming, ranching, & growing) flare stack, platform,
tower, pole, and pipeline infrastructure, structures, sites, systems, features and operations; and,

2.) Environmental, scientific, conservation, climate change, natural

resource, wildl ife, oceanographic, forestry, weather, search & rescue, emergency services, humanitarian relief, public & private entity support, assistance and monitoring
of infrastructure, structures, sites, systems, features, and operations; and,

3.) Research, educat ion, training, development, testing, certification, and validation of safe and lawful commercial, hobby, and recreational UAS curriculum, education, and safe flight training , demonstrations, and events involving UAS design, manufacture, assembly, purchase, sale, maintenance, repair, inspection, safe operation, record keeping, and required FAA documentation.

Hereinafter, 1

, 2 , and 3 , above, referred to as petitioner’s "proposed operations".

### Larsen 333 Petition

July 16, 2015 P a g e | 3 of 12 In support of his application, petitioner confidentially submits h is proprietary Flight Operations Manual (FOM) and a flight manual for his DJI Phantom 2 Vision+ (P2v)

. Petitioner’s P2v UAS has been duly registered with the FAA which has assigned registration
number N558WC

.

Specific Regulations f or which an exemption is sought:

14 CFR 61.113 (a) 14 CFR 91.7 (a) 14 CFR 91.119 (b) & (c)

14 CPR 91. 121 14 CFR 91.151 (a) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CPR 409 (a) (1) & (2) 14 CFR 417 (a) & (b)

II. PETITIONER’S PROPOSED OPERATIONS DO NOT CREATE SIGNIFICANT
HAZ ARDS

The P2v UAS utilized by Petitioner is an electric multi

- rotor craft, weighing less than 55 lbs. including ADC payload. It operates at a speed of no more than 100 mph (87 knots) and has the capability to hover, and/or move in a vertical and horizontal plane simultaneously. It will only be operated as visual line of sight (VLOS), remain under 400 ft. above ground level (AGL), and will operate only over private or controlled access property with permission from the owner/controller of the property or aut horized representative.

During petitioner’s proposed operations the site will be secured and non

- participants will be kept at least 500 feet away from the operation unless barriers or structures are present that sufficiently protect non

- participants in th e event of an accident or loss of control. Petitioner has drafted, and submits confidentially, his Flight Operations Manual (FOM) which discusses safety considerations, training, general operating procedures, specifications, inspection, maintenance, setup of the UAS, and other proprietary procedures for the proposed UAS operations.

III. PETITIONER LARSEN'S PROPOSED OPERATIONS ARE IN THE PUBLIC
INTEREST

The FAA has issued a Grant of Exemption to FalconSkyCam for operations that are substantially similar to t hose proposed herein. Docket No. FAA

- 2014

- 0884 (March 6, 2015). In issuing the Grant, the FAA noted that "[t]he enhanced safety and reduced environmental impact achieved using a UAS with the specifications described by the petitioner and carrying

no passen gers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the public interest."

### Larsen 333 Petition

July 16, 2015 P a g e | 4 of 12 Accordingly, Petit ioner respectfully requests that the FAA grant the requested exemption summarily and without delay.

IV. EQUIVALENT LEVEL OF SAFETY

Petitioner proposes that his P2v UAS requested exemption with the characteristics and as operated with the limitations listed below, provide for at least an equivalent or even higher level of safety to operations under the current regulatory framework.

These limitations and conditions to which Petitioner agrees to be bound when conducting commercial operations under an FAA issu ed exemption include:

1.) The P2v UAS utilized by Petitioner will weigh Less than 55 lbs, operate at a speed of no more than 100 mph (87 knots), and will remain under 400 ft. (AGL). 2.) Flights will be operated only during daylight hours, only in visual meteorolo gical conditions, and only within visual line of sight (VLOS) of the pilot in command (PIC)
of the UAS. 3.) All operations will utilize a visual observer (VO) in addition to the pilot in command (PIC). 4.) Maximum total flight time for each operational flight will be approximately 30 minutes, or when the Low Battery warning activates.

V. EXEMPTIONS REQUESTED

14 C.F.R. § 61.113 (a) and (b): Private, Recreational, or Sport vs. Commercial Pilot
Certificates

Sections 61.113 (a) and (b) prohibit private , recreational, o r sport certified pilots from operating a traditional aircraft for compensation or hire. Petitioner proposes that his PIC will have at least a private , recreational, or sport pilot’s certificate, and a current FAA
medical certificate or a valid U.S. driver ’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. Petitioner’s PIC will also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the
PIC is rated o n his or her pilot certificate.

Petitioner will not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under petitioner’s exemption, including evasive and e mergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency will be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the peti tioner’s PICs and VOs (training, proficiency, and experience

building) and determining the PIC’s ability to safely operate the UAS in a manner consistent
with how the UAS will be operated under petitioner’s exemption are requested by petitioner to be allow ed under the terms of this exemption.

### Larsen 333 Petition

July 16, 2015 P a g e | 5 of 12 Petitioner further proposes that such PIC and VO training operations will only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations will be considered nonparticipants, and the PIC will operate the UA with appropriate distance from nonparticipants in accordance with 14 CFR § 91.119.

Based upon the above and for the reasons set forth in the FAA's grant of an exemp tion to Astraeus Aerial, Petitioner does not believe a commercial pilot certificate is necessary for the operations it intends to conduct. See, e.g., In the matter of the petition of Astraeus Aerial, Exemption No. 11062 (issued Sept. 25, 2014). For those r easons, Petitioner requests an exemption from 14 C.F.R. § 61.113 (a) and (b).

As the petitioner’s preferred alternative exemption to the above PIC pilot rating and

cer tification requirements Petitioner respectfully requests an exemption from the manned

ai rcraft flight proficiency sport pilot cert ificate requirements of 14 CFR § 91.119; §61.311 ; and §61.313 (and any similar provisions as best determined by the FAA). Specifically, petitioner requests that his PIC be exempted only from having to actually pi lot a full sized
traditional aircra ft as an essential part of UAS PIC qualifications, certification, and training to
become FAA certified as a P2v UAS PIC for the proposed operations.

Currently to obtain a s port pilot certification about 25 hours of actua l manned aircraft pilot flying experience with an instructor is required. Five hours of flying solo. Fifteen hours of ground instruction. And

, about 25 hours of home study. Costs vary by location . P etitioner reasonably estimates his costs would be approxim ately $6,500 to obtain a s port pilot
certification.

Having to pilot a large, manned, traditional, aircraft as a condition to FAA authorization to operate petitioner’s P2v UAS, respectfully, seems to be unnecessarily unsafe, hazardous,
and does not relate to a UAS PIC’s fitness or skill set reasonably required to safely and competently operate petitioner’s P2v UAS. Instead, Petitioner respectfully requests that his PIC be required to meet all of the exact same aircraft ground school training and testing as is currently required to obtain a recreational or sport pilot (sport pilot) certification.

It is understood that all UAS operators, both recreational and commercial, need to have a clear understanding of the National Airspace System (NAS) and of safe and competent UAS operations. That knowledge can be verified by operator attending FAA private pilot ground instruction and by pa ssing FAA Private Pilot written examination for sport pilot or above and logged UAS training. That should be reasonably safe and su fficient. Why would an operator need flight experience as a pilot of a full sized manned aircraft to operate a 3 pound UAS P2v quad

- copter?

Requiring petitioner to hire a PIC (who may have no skills in flying a small UAS) or having to
bear the time and ex pense of completing pilot flight proficiency training in a manned

### Larsen 333 Petition

July 16, 2015 P a g e | 6 of 12 aircraft, is an unfair burden to place on petitioner, who is faced with overwhelming competition from unauthorized operators who openly ignore FAA commercial UAS policy.
The standard PIC man ned aircraft flight proficiency requirements for a small UAS operator
which have been applied to past applicants for exemptions is unfair, unnecessary and excessively unsafe.

Moreover, in further support of petitioner’s request for exemption, petitioner p roposes that his PIC shall undergo the exact same background check and meet the same citizenship

or permanent residency requirements as are currently required for FAA sport pilot certification. Petitioner maintains that a greater level of safety will be ma intained in the

NAS and far less risk of personal injury , damage, and danger to the public and to petitioner’s PIC will result by exempting petitioner’s PIC from unnecessarily having to personally pilot a large, traditional, manned aircraft in the NAS as a n essential part of the FAA required P2v

UAS pilot qualifications, certification, and training.

In addition, petitioner proposes t hat his PIC shall undergo thirty (3 0) hours of lo gged UAS flight training, fifteen (15 ) hours of which shall be on the partic ular P2v UAS to be used in the proposed operations. As part of petitioner’s PIC training the PIC will be required to safely conduct at least five (5) takeoffs and five (5) landings with the particular UAS to be used by the PIC in petitioner’s proposed oper ations.

In N 8900.227 National Policy, “ Unmanned Aircraft Systems (UAS) Operational Approval ” the FAA in pertinent part has said (emphasis added):

a. 

### “ UAS Pilot Qualifications . The FAA is focused on ensuring that UAS pilots have an appropriate level of und erstanding of 14 CFR applicable to the airspace where UAS operate. UAS pilots are responsible for controlling their aircraft to the same standards as the pilot of a manned aircraft. Civil UAS pilots may be required to have instruction by an
FAA

- certificate d flight instructor.

. . . .

(2) PIC Rating Requirements. Rating requirements for the UAS PIC depend on the type of operation conducted; they fall into two categories:

 Operations that require at least a private pilot certificate or FAA

- recognized equivalent, or

 Operations that do not require at least a private pilot certificate or FAA

- recognized equivalent.

(a) The requirement for the PIC to hold a pilot certificate or FAA

- recognized equivalent is based on various factors including:

 The location of the planned operations,

 The mission profile,

 The size of the aircraft, and

 Whether or not the operation is conducted within or beyond visual line

- of

- sight.

### Larsen 333 Petition

July 16, 2015 P a g e | 7 of 12 (b) The PIC must hold, at a minimum, an FAA private pilot certificate or FAA

- recognized equivalent for all operatio ns listed below:

 Flight in Class A, B, C, D, E, and G (400 feet above ground level (AGL)) airspace.

 IFR (must have instrument rating) operations.

 Night operations.

 At joint use or public airfields.

 Requiring a chase aircraft.

 At any time the FAA has deter mined the need, based on the UAS characteristics, mission profile, or other operational parameters.

(c) Operations without a pilot certificate may be allowed when all of the following conditions are met:

 The PIC has successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA

- recognized equivalents. (Airman Test Reports are valid for the 24 calendar

- month period preceding the month the exam was completed, at which time the instruction a nd written examination must be repeated.)

 Operations are during daylight hours.

 The operation is conducted in a sparsely populated location.

 Operations are approved and conducted solely within visual line

- of

- sight in Class G airspace.

 Visual line

- of

- sight operations are conducted no further than 1⁄2 NM laterally from the UAS pilot and at an altitude of no more than 400 feet AGL at all times. Refer to Appendix A for the visual line

- of

- sight definition.

 Operations are conducted no closer than 5 NM from any FAA

- designated airport or heliport other than the airport from which the aircraft is operating.

 The operation is conducted from a privately owned airfield, military installation, or off

airport location.

(3) PIC Recent Flight Experience (Currency). The proponent must provide documentation showing the pilots maintain an appropriate level of recent pilot experience in the UAS being operated, or in an FAA

- certified simulator. At a minimum, the PIC must conduct three takeoffs (launch) and three landings (recovery) in the specific UAS within the previous 90 days (excluding pilots who do not conduct launch/recovery during normal/emergency operations); or as prescribed by the proponent’s accepted recurrent training and currency program

. 

### ”

Petitioner proposes in this petit ion for exemption (and operating documents) to restrict his proposed P2v UAS operations to include:

 The PIC has successfully completed, at a minimum, FAA sport pilot ground school instruction and passed the FAA Sport Pilot written examination (and backgro und checks) or FAA

- recognized equivalents, and holds a current FAA medical certificate or
a valid US Driver ' s License.

 P2v UAS operations only during daylight hours.

### Larsen 333 Petition

July 16, 2015 P a g e | 8 of 12  P2v UAS operations only in sparsely populated locations.

 P2v UAS operations to be conduct ed solely within visual line

- of

- sight in Class G airspace.

 P2v UAS Visual line

- of

- sight operations to be conducted no further than 1⁄2 NM laterally from the UAS pilot and at an altitude of no more than 400 feet AGL at all times. P2v UAS operations will be co nducted no closer than 5 NM from any FAA

designated airport or heliport other than the airport from which the UAS aircraft is operating.

Under the circumstances presented in this petition for exemption, petitioner respectfully
submits that it is without b asis in law and unreasonable, arbitrary, and capricious for the FAA to require petitioner’s PIC to be compelled to first pilot a large, traditional, manned aircraft as an essential part of FAA required UAS PIC qualifications, certification, and training.

Petitioner further respectfully submits that the FAA requirement of having to first pilot a large, traditional, manned aircraft as an essential part of FAA required UAS PIC qualifications, certification, and training violates the provisions of the America ns with Disabilities Act of 1990 (ADA), 42 USC §12101 et seq. This piloting of full size manned aircraft in the NAS, FAA UAS PIC training requirement also prevents or discourages petitioner from hiring perfectly competent, skilled, and able UAS PICs to ser ve as PICs, who would otherwise be equally, or even superiorly, qualified to operate petitioner’s P2v UAS.
For all of these reasons, Petitioner respectfully requests that this very limited alternative exemption from 14 C.F.R. § 61.113 (a) and (b) be grante d for the proposed operations as

FAA

- recognized equivalent UAS PIC certification , in the public interest.

14 C.F.R. § 91.7 (a): Civil Aircraft Airworthiness

Section 91.7 prohibits operation of an unairworthy aircraft, and places responsibility for

airwor thiness determinations on the PIC. The UAS will not have an airworthiness certificate, and there is no FAA regulatory standard for determining airworthiness of the UAS. Additionally, Petitioner's operating documents, including FOM, set forth inspection and maintenance procedures to ensure airworthiness. For these reasons, and in accordance with the FAA's grant of an exemption from section 91.7 to Total Safety U.S., Inc., Petitioner requests an exemption from 14 CFR. § 91.7(a). See, e.g., In the matter of th e petition of Total Safety U.S., Inc., Exemption No. 11156 (issued Jan. 29, 2015).

14 C.F.R. §91.119 (b) and (c): Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (b) prohibits aircraft in c ongested areas from flying less than 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. To the extent that Petitioner’s proposed operations would be considered to be in "congested areas," Petitioner's operationa l procedures, including FOM, and the size, weight and speed of the

### Larsen 333 Petition

July 16, 2015 P a g e | 9 of 12 P2v UAS, provide an equivalent level of safety such that the proposed operations at lower
altitudes should be allowed.

As described in his Flight Operations Manual (FOM), Petitioner will e stablish a 500' buffer/sterile area for its operations that will exclude personnel not associated with the operations. Petitioner will also exercise additional control over the sterile area as needed, as set forth in the FOM. Consequently, Petitioner belie ves these procedures will reduce or eliminate any potential adverse impacts to safety for operations in congested areas. Petitioner therefore requests an exemption from 14 CFR § 91.119(b).

Section 91.119 (c) prohibits operations in other than congested a reas below 500 feet above the surface, or closer than 500 feet to any person, vessel, vehicle or structure. Since this exemption is for a UAS that flies similarly to a helicopter and requests authority to operate at altitudes up to 400 AGL, an exemption ma y be needed to allow such proposed operations.

The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it is operated. As discussed above, Petitioner’s FOM provides for
establishment of a ster ile area, including safety buffers of 500 feet for personnel not associated with the operation. Petitioner therefore requests an exemption from Section 91.119(c) for all authorized personnel associated with the proposed operations.

14 C.F.R. §91.121 Altim eter Settings

This regulation requires each person operating an aircraft to maintain a 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 ." As the UAS may not have a barometric altimeter, but instead a constant GPS altitude read out, an exemption is requested.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

Section 91.151 (a) prohibits an individual from beginning "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

- (1) During the day, to fly after that for at lea st 30 minutes; or (2) At night, to fly after that for at least
45 minutes."

Maximum total flight time for each of the proposed operations will be no more than 30 minutes. Flights will be safely landed when the battery falls below its nominal voltage,
shou ld that occur prior to completion of the operation. The petitioner’s P2v UAS has a constant battery voltage display and a Low Voltage LED Warning which alerts when the battery reaches pre

- determined levels. This battery level would be more than adequate to

### Larsen 333 Petition

July 16, 2015 P a g e | 10 of 12 return the UAS to its planned landing zone from anywhere in its limited operating area when the Low Voltage Warning alerts.

For these reasons, Petitioner requests an exemption from 14 C.F.R. § 91.151 (a). Similar exemptions have been granted to other ope rations, including Exemptions 2689F, 5745, 10673, and 10808.

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

These regulations require that an aircraft operator or owner "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 of this chapter ...," and others shall inspect or maintain the aircraft i n compliance with Part 43.

As provided in petitioner’s FOM, the operator and the PIC will ensure that the UAS is in working order prior to initiating each flight, and the operator will perform required maintenance and inspections, and keep a log of any ma intenance performed.

VI. REGULATIONS FOR WHICH EXEMPTIONS ARE UNNECESSARY

The Federal Aviation Administration (FAA) has issued numerous prior exemptions for many different types of UAS operations. In those exemptions, the agency noted that exemptions
from ce rtain regulations were not necessary, due to "the size, weight, speed and limited operating area associated with [the UAS] and its operation."

Based upon the FAA's guidance and the fact that petitioner’s UAS is even smaller and slower than many of those U AS in previously issued exemptions, Petitioner believes exemptions from the following regulations are not necessary:

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates. 14 C.F.R. § 45.23 (b): Marking of the Aircraft. 14 C.F.R. §91.7(b): Civil aircr aft airworthiness. 14 C.F.R. §91.109: Flight instruction.

Petitioner also believes that an exemption from 14 C.F.R. § 91.103: Preflight Action is not necessary. This regulation requires each pilot in command to take certain actions before flight to insur e the safety of flight. An FAA approved rotorcraft flight manual will not be provided for the aircraft. An equivalent level of safety will be provided as set forth in the FOM and operating documents submitted as part of this request.

The FAA has previousl y found that adherence to procedures contained in an applicant's operating documents demonstrate compliance with § 91.103, and therefore an exemption

### Larsen 333 Petition

July 16, 2015 P a g e | 11 of 12 from the regulation was not necessary. See, e.g., In the matter of the petition of Total Safety U.S., Inc. , Exemption No. 11156 (issued Jan. 29, 2015).

As detailed in his operating documents, petitioner's PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff clearance distances and aircraft performance data be fore initiation of flight to ensure the safety of the flight. Consequently, in light of this agency's prior finding in Total Safety U.S., Inc., Petitioner does not believe an exemption from 14 C.F.R. § 91.103 is necessary.

If it is determined that the p etitioner does require exemptions from any of the above provisions from which he has herein stated that he believes no exemption is required: Petitioner requests that such exemptions be granted upon the basis of all that he has stated in this petition

.

Pu rsuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed:

Petitioner seeks an exemption from the following rules: 14 C.F.R. § 61.113 (a) and (b); 91.7 (a); 9 1.119 (b) and (c); 91.121; 91.151 (a);

91.405 (a); 91.407 (a) (1); 91.409 (a) (1) & (2) and 91.417 (a) & (b) to conduct aerial data collection (ADC) which includes any remote sensing and measuring by an instrument(s) aboard the Unoccupied (Unmanned) Aircra ft (UA). Examples include imagery (photography, video, infrared, etc.), electronic measurement (precision surveying, RF analysis, etc.), chemical measurement (particulate measurement, etc.), or any other gathering of data by instruments aboard the

UA.

App roval of exemptions allowing commercial operations of UAS for these purposes will enhance safety by reducing risk. Conventional means for performing these assessments require either physically climbing or scaling structures, poles or towers, using ropes to scale or rappel up or down poles, towers or structures, using high

- reach man lifts to access the towers, poles, sites, or structures (limited reach), or by using conventional helicopters or traditional aircraft operating at extremely low altitudes over th e subject structure, pole, site, or tower being examined. These conventional means all pose high risks to persons and property, including many actual human deaths each year.

In contrast, a UAS weighing less than 55 lbs. and powered by batteries,
eliminate s virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The UAS is carried by hand to the proposed operations site and not flown. The UAS carries no passengers or crew and, therefore, will not expose them to the r isks associated with traditional manned aircraft flights; ground based aerial lift (bucket truck) operations, or manual climbing, scaling, and inspection operations.

### Larsen 333 Petition

July 16, 2015 P a g e | 12 of 12 The proposed operations of this small P2v UAS, weighing less than 55 lbs.,
conducted in t he strict conditions outlined in this petition, will provide an equivalent level of safety supporting the grant of the exemptions requested, including exempting Petitioner from the requirements of Part 21 and allowing commercial UAS operations. These light weight aircraft operate at slow speeds, and close to the ground, and, as a result, are far safer than the conventional
alternatives.

Privacy All of the proposed operations, UAS flights, will occur only over private or controlled access property with permi ssion from the owner/controller of the property or authorized representative. Petitioner’s proposed operations will be
conducted in accordance with all applicable laws and regulations governing privacy at the venue of the flight operation.

VII. CONCLUSIO N

Petitioner has requested to use a P2v UAS for aerial data collection (ADC). The FAA has issued grants of exemption in circumstances similar in all material respects to those presented in this petition. In Grants of Exemption Nos. 11062 to Astraeus Aeria l ( see Docket

No. FAA−2014−0352), 11109 to Clayco, Inc. ( see Docket No. FAA−2014−0507), 11112 to VDOS Global, LLC ( see Docket No. FAA−2014−0382), and 11213 to Aeryon Labs, Inc. ( see Docket No. FAA−2014−0642), the FAA found that the enhanced safety achieved using an
unmanned aircraft (UA) with the specifications described by the petitioner and carrying no

passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cau se to find that the UAS operation enabled by granting an exemption to petitioner is in the public interest.

Upon review of petitioner’s reasons for requesting this exemption, It reasonably should be
determined that:

1.) They are similar in all material respe cts to relief previously requested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213; 2.) The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situation petitioner presents; and 3.) A grant of exemption is in the public interest.

Therefore, pursuant to the authority contained in 49 U.S.C. 106(f), 40113, and 44701, Petitioner should be granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91 .121, 91.151(a)(1), 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b), to the extent necessary to allow the pe titioner’s proposed operations and preferred alternative PIC training and
certification.

### Larsen 333 Petition

July 16, 2015 P a g e | 13 of 12 Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012

- size, weight, speed, operating capabilities, proximity to airports and populated areas and daylight UAS operation s to within visual line of sight (VLOS) and national security

- provide more tha n adequate justific ation to grant the requested exemptions allowing the proposed operations in the NAS by petitioner Erick F. Larsen

.

Respectfully,



## Erick F. Larsen

262 W. Linden Ave. # C Burbank, LA, Ca 91502

818

- 732

- 0330 ErickLarsen@Outlook.com