Eric Williams

CEO

Udrone Air dba

7315 Wilcox Drive Dallas, Texas 75232

469

- 212

- 6804

June 4 , 2015

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

Re : Exemption Request; Section 333 of the FAA Modernization & Reform Act and Part 11 of the Federal Aviation Regulations from 14 C.F.R. 45.23(b);14 CFR Part 21;14 CFR61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103(b); 91.109; 91.119; 91.121; 91.151 (a); 91.203(a) & (b); 91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b).

To: Secretary of Transportation

UdroneAir d

b a hereby petitions the Secretary of Transportation and Federal Aviation Administration ("FAA") for exemption to the above referenced and below more fully

described Federal Avi ation Regulations, ("FARs") that currently may or may not apply to the recreational/ business operations of model aircraft including small unma nned aerial vehicles/systems ("sUAS ").

UdroneAir is aware the FAA has granted similar exemptions for aerial pho tography and is on the verge of granting similar exemptions.

2. Petition for Exemption

P ursuant to Section 333 of the FAA Modernization and Reform Act of 2012 ("FMRA") and 14 C.F.R. Part 11, UdroneAir developer and operator of small unmanned aerial

v e hicles (" sUAS ") equipped to conduct aerial photography/Inspection/ included but not limited to the following;1. Safety & Education training RC UAS flight simulators

2. Television productions, music video productions , advertising and news gathering.

3

. Marketing of residential and commercial real estate

4 . Inspection surveys i.e. a gricultural land for farmers, roofing, oil & gas companies, s hore line protection for e cologi cal concerns

5

. Assist local law enforcement in emergency matters, ove r land, wa ter

- ways, and oceans, disaster relief , medical supplies delivery and missing persons.

6 . State side virtual tours

As described more fully below, the requested exemption would permit the operation of

sUAS under controlled conditions in airspace t hat is 1) limited 2) predetermined; and 3)

controlled as to access.

This exemption w ill also provide safety enhancements to the already safe operations within the aerial photography industry presently using conventional aircraft and small,

unmanned and relatively inexpensive sUAS

.

Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administra tor's) responsibilities to " establish requirements for the safe operation of such aircraft systems in the national airspace system." Section 333(c) of the FMRA.

3.

UdroneAir

Eric Williams

7315 Wilcox Drive Dallas, Texas 75232 udroneair@yahoo.com

www.udroneair.com

460

- 21 2

- 6904

4. Regulations Petitioner Petitions for Exemption, If Such Regulations Apply to sUAS.

14 CFR Part 21

14 C.F.R. 91.109 14 CFR 91.405 (a) 14 C.F.R. 45.23(b)

14 C.F. R. 91.119 14 CFR 407 (a) (1) 14 CFR 61.113 (a) & (b)

14 C.F.R. 91.121

14 CFR 409 (a) (2) 14 C.F.R. 91.7 (a) 14 CFR 91.151 (a) 14 CFR 417 (a) & (b) 14 CFR 91.9 (b) (2) 14 CFR 91.203 (a) & (b)

14 C.F.R. 91.103This exemption application is expressly submitted to fulfill the goals in passing

Section 333 (a) through (c) of the Reform Act.

This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system ("NAS") before completion of the rulemaking required under Section 332 of the FMRA. In making this determination, the Secretary is requir ed to determine which types of s UAVS/UAS do not create a hazard to users of the NAS, or the public, or pose a threat to national security in light of the following:

A. The s sUAS s size, weight, speed, and operational capability; B. Operation of the s sUAS in close proximity to airports and populated areas;

and C. Operation of the s sUAS within visual line of sight of the operator. FMRA § 333 (a)

If, the Secretary determines that such vehicles "may op erate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." /d. §333(c) (emphasis added).

UdroneAir interprets this provision to place the duty on the Secretary/FAA Administrator to not only process applications for exemptions under section 333, but for the Secretary/Administrator to affirmatively craft conditions for the safe operation of the

s sUAS , if it should be determined that the conditions set f orth herein do not fulfill the statutory requirements for approval.

The Federal Aviation Act expressly grants the Secretary/FAA Administrator the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, a s the term is defined under §401 01 of the Act, which currently ma y or hereafter may include s sUAS , from the requirement that all civil aircraft must have a current

airworthiness certificate.

The Secretary/FAA Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702

- 44716 of this title if the Secretary/FAA Administrator finds the exemption in the public interest. 49 U.S.C. §44701 (f) See also 49 USC §44711 (a); 4 9 USC §44704; 14 CFR §91.203 (a) (1).

UdroneAir sUAS are small multi

- rotorcraft equipped with an on board NAZA computer stabilization controller and GPS, weighting 55 lbs or less and most typically less than 10 lbs., including camera/payload. They oper ate, under normal conditions, at speeds of 5

- 40 KIAS and at speed of no more than 50 KIAS and have the capability to hover and move in th e vertical and horizontal plane independently/simultaneously.

They will operate in line of sight and will operate onl y within the areas described herein. Such operations will insure that the s sUAS will "not create a hazard to users of the NAS or the "public" as described in the FMRA §333(b).Given the small size of the sUAS involved, and the limited environment with in which

they will operate, UdroneAir falls squa rely within that zone of safety in which Congress envisioned that the FAA must, by exemption, allow commercial operations of sUAS to commence immediately.

Also, due to the size of the sUAS and the restric t ed areas in which the relevant sUAS will operate, approval of the application presents no national security issue.

Given the clear direction in FMRA §333, the authority contained in the Federal Aviation Act, as amended, the strong equivalent level of s afety surrou nding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts (including reduced emissions associated with allowing sUAS for filming operations rather than full

- sized aircraft, the grant of the requested exemptions is in the public interest.

Accordingly, UdroneAir respectfully requests that the FAA grant the requested exemption without delay.

5. Limitations and Conditions

UdroneAir proposes that the exemption requested here in be issued pursuant the limitations and conditions listed herein. These conditions/limitations provide for an even higher level of safety to operations under the current regulatory structure which apply to actual certificated aircraft because the propos ed operations represent a safety enhancement to the already very safe sUAS filming operations conducted by recreational

sUAS and conventional aircraft.

UdroneAir primary mission includes but are not limited to marketing of residential and

commercial r eal estate, inspection/survey of agricultural land for Farmers, Shoreline protection for ecological concerns, television and news coverage, assist local law enforcement in emergency matters.

UdroneAir business locations shall be primarily in the US

. The se conditions to which

UdroneAir agrees to be bound when conducting business/commercial operations under this FAA issued exemption are consistent with the administrators grant of e xemption to the MPAA, include:

1. The sUAS weighs less than 55 pounds (25 Kg), including energy source(s) and equipment. Operations authorized by this grant of exemption are limited to the following

aircraft: Cheerson CX 20 quadcopter.

2. The sUAS will not be flown at a speed exceeding a ground speed of 50 knots.

3. Flights will be operated at an altitude of no more than 400 feet above ground level (AGL), as indicated by the procedures specified in the operator's manual. All altitudes reported to ATC must be in feet AGL.4. The sUAS will be operated within visual line of sight (VLOS) of the Operator at all

times. This will require the o perator to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC's FAA

- issued medical

certificate.

5. All UdroneAir operations will utilize a visual observer (VO). The VO may be used to satisfy the VLOS requirement, as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times.

6. The operator's checklist is considered acceptabl e to the FAA, provided the additional Requirements identified in these conditions and limitations are added or amended. The operator's checklist and this grant of exemption must be maintained and made available

to the a dministrator upon request. If a di screpancy exists between the conditions and limitations in this exemption and the procedures outlined in the checklists the conditions and limitations herein take precedence and must be followed. Otherwise, the operator

will follow the procedures as out lined in its checklists.

The operator will update or revise its operator's checklists. It will be the operator's Responsibility to track such revisions and present updated and revised documents to the

a dministrator upon request. The operator will prese nt updated and revised

documents if UdroneAir petitions for extension or amendment. If the operator determines that any update or revision would affect the basis for which the FAA granted this exemption, then the operator must petition for amendment to t heir exemption. The

FAA's s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operator's manual.

7. Prior to each UdroneAir flight the PIC will inspect the sUAS to ensure it is in a

condition for sa fe flight. If the inspection reveals a condition that affects the safe operation of the sUAS , the aircraft will be prohibited from operating until the necessary maintenance has been performed and the sUAS is found to be in a condition for safe flight. The Ground Control Station, will be utilized, and included in the preflight inspection. All maintenance and alterations will be properly documented in the aircraft

records.

8. Any UdroneAir sUAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component,

will undergo a functional test flight in accordance with the operator's manual. The PIC

will conduct the functional test flight and will make an entry in the s UAS a ircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the operator's manual.

9. UdroneAir operator s will follow the manufacturer's sUAS aircraft/component, maintenance, over haul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/ component/overhaul, replacement, and inspection/maintenance requirements will be established and identified in the operator's manual. At a minimum, the foll owing must be included in the operator's manual:a. Actuators I Servos

b. Transmission (single rotor) c. Powerplant (motors) d. Propellers e. Electronic speed controller

f. Batteries g. Mechanical dynamic components (single rotor)

h. Remote com mand and control i. Ground control station (if used) j. Any other components as determined by the operator

10. The operator in command (OIC) will own a certificate for the satisfactory completion of the ground

- flight school portion

.

11. Prior to Udro ne Air operations conducted for the purpose of motion picture filming (or similar operations), the OIC will have accumulated and logged, in a manner

consistent with 1 4 CFR § 61.51 (b), a minimum of 25 hours of total time as a sUAS rotorcraft pilot and at l east ten hours logged as a sUAS pilot with a similar sUAS type (single blade or multi rotor). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under this grant of exemption to accomplish the required flight cycles and flight time. During training, proficiency, and experience

- building flights, all persons not essential for flight operations

will be considere d non

- participants, and the PIC will operate the sUAS with appropriate

distance from non

- participants in accordance with 14 CFR § 91.119. Prior to operations conducted for the purpose of motion picture filming (or similar operations), the OIC must

have acc umulated and logged, in a manner consistent with 14 CFR § 61.51 (b), a

minimum of five hours as sUAS pilot o perating the make and model of sUAS to be utilized for operations under the exemption and three take

- offs and three landings in the preceding 90 day s. Training, proficiency, experience

- building, and take

- off and landing currency flights will be conducted under this grant of exemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience

building, and take

- off and landing currency flights all persons not essential for flight operations are considered non

- participants, and the PIC must operate the UA with appropriate distance from non

- participants in accordance with 14 CFR § 91.119.

12. Prior to UdroneAir operations conducted for the purpose of motion picture filming (or similar operations), a flight demonstration, administered by an operator

- approved and

- qualified pilot must be successfully completed and documented.

13. The sUAS will not be operated dir ectly over any person, except authorized and consenting production personnel, below an altitude that is hazardous to persons or property on the surface in the event of a sUAS failure or emergency.14. Regarding the distance from participating pers ons, the operator's manual has safety

mitigations for authorized and consenting product ion personnel. At all times, the se

persons will be essential to the closed

- set film operations. Because these procedures are specific to participating persons, no fur ther FSDO or Aviation Safety Inspector (ASI) approval is necessary for reductions to the distances specified in the petitioner's manuals. This is consistent with the manned aircraft procedures described in FAA Order 8900.1, V3, C8, S1 Issue a Certificat e of Waiver for Motion Picture and Television Filming.

15. The sUAS will not be operated directly over any person, except authorized and consenting production personnel, below an altitude that is hazardous to persons or property on the surface in the event of a sUAS failure or emergency.

16. Regarding distance from non

- participating persons, UdroneAir operator s will ensure that no persons are allowed within 500 feet of the area except those consenting to be involved and necessary for the filming prod uction. This provision may be reduced to no less than 200 feet if it would not adversely affect safety and the Administrator has approved it. For example, an equivalent level of safety may be determined by an aviation safety inspector's evaluation of the f ilming production area to note terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect non

- participating persons (observers, the public, news media, etc.) from debris in the event of an

accident. This is also consisten t with the same FAA Order 8900.1, V3, C8, S1.

17 .If the sUAS loses communications or loses its G PS signal, the sUAS will return to a

pre

- determined GPS location within the security perimeter and land or be recovered.

18. The sUAS OIC will abort the fl ight in the event of unpredicted obstacles or emergencies. The Operator will carry/use appropriate LIPO battery protective bags and fire extinguishing equipment.

19. Each sUAS operation will be completed within 30 minutes flight time or with 25%

batte ry power remaining, whichever occurs first.

20.1n addition to the conditions and limitations proposed by the operator, the FAA has determined that any operations conducted under this grant of exemption must be done pursuant to the following conditions and limitations:

21. UdroneAir operator s will obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (GOA) prior to conducting any operations under this grant of exemption. This GOA will also require the operator to reques t a Notice to Airman (NOT AM) not more than 72 hours in advance, but not less than 48 hours prior to the operation.

22. All UndroneAir aircraft operated in accordance with this exemption will be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable.23. The OIC will develop procedures to documen t and maintain a record of the sUAS

maintenance, prevent ative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service of the sUAS . These procedures must be added to the operator's manual/checklists.

24. Each sUAS operated under this exemption will comply with all manufacturer Safety

Bulletins.

25. The OIC will develop sUAS technician qualification criteria. These criteria will be added to the operator's manual/Checklists.

26. The preflight inspection section in the operator's checklists manual will be ame nded to include the following requirement: The preflight inspection will account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operator's manual.

27. Before cond ucting UdroneAir operations, the radio frequency spectrum used for operation and control of the sUAS will comply with the Federal Communications Commission (FCC) or other appropriate government oversight agency requirements.

28. At least three days befor e sch eduled filming, the OIC of the sUAS affected by this exemption will submit a written Plan of Activities to the local FSDO with jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the

concurrence of the FSDO. Th e plan of activities will include at least the following:

a. Dates and times for all flights b. Name and phone number of the operator for the sUAS filming production conducted under this grant of exemption c. Name and phone number of the person respo nsible for the on

- scene operation of the

sUAS d. Make, mo del, and serial or N

- number of sUAS to be used

e. Name and certificate number of sUAS PICs involved in the filming production event f. A statement that the UdroneAir operator has obtained permis sion from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request. g. Signature of exemption

- holder or representative h. A description of t he flight activity, including maps or diagrams of any area, city, town, county, and/or state over which filming will be conducted and the altitudes essential to accomplish the operation

29. The documents required under 14 CFR § 91.9 and § 91.203 will b e available to the OIC at the ground control station of the sUAS any time the aircraft is operating. These

documents will be made available to the a dministrator or any law enforcement official

upon request.

30. The sUAS will remain clear and yield th e right of way to all other manned operations and activities at all times (including, but not limited to, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.).31. UdroneAir sUAS operations may be conducted during nigh t, as defined in 14 CFR §

1.1. All operations will be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) will not be permitted.

.

32. The sUAS will not be operated by the OIC from any moving device or vehicle.

33. The sUAS will not be operated less than 2 00 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

34.The sUAS will not operate in Class B, C, or D airspace without writte n approval from

the FAA. The sUAS will not operate within 5 nautical miles of the geographic center of a

non

- towered airport as denoted on a current FAA

- published aeronautical chart unless a letter of agreement with that airport's management is obtained , and the operation is conducted in accordance with a NOT AM as required by the operator's GOA The letter of agreement with the airport management will be made available to the Administrator

upon request.

35.Any 1) incident, 2) accident, or 3) flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable GOA will be reported to the Federal Aviation Administration's (FAA) UAS Integration Office (AFS

80) within 24 hours. Accidents will be repor ted to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. Further flight operations will not be conducted until the incident, accident, or transgression is reviewed by AFS

- 80 and authorization to resume operations is provided. Unless otherwise specified in this grant of exemption, the SUAV, and operator must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

6. Description of Regulations Which Ma y Apply From Which Petitioner Requests Exception 14 C.F.R. Part 21, Subpart H: Airworthiness Certi ficates 14 C.F.R. §91.203 (a) (1)

Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements

for the issuance of airworthines s certificates as required by FAR §91.203 (a) (1). Given

the size and limited operating area associ ated with the sUAS to be utilized by the Petitioner, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 1 1 and Section 333 of the FMRA. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the FMRA both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operat ional capability, and proximity to airports and populated areas of the particular sUAS . In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and

under the conditi ons proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the restrictions and conditions proposed.The sUAS to be operated hereunder is less than 55 lbs . fully loaded, is by definition

unmanned and carries neither a pilot nor passenger, carries no explosive materials or flammable liquid fuels, and operates exclusively within a limited f light area. Unlike other

civil aircraft, operations under this exemp tion will be tightly controlled and monitored by the PIC/Operator and will also remain within the requirements of, and in compliance with, local public safety requirements. These safety enhancements, which already apply to civil aircraft provide a greater degree of safety to the public and property owners than conventional operations conducted with airworthiness certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same criteria demonstrates that there is no

credible threat to national security posed by the UAS due to its size, speed of operation, location of operation, lack of explosive materials or flammable liquid fuels, and inability to carry a substantial external load.

14 C.F.R. § 45.23 (b). Marking of the Aircraft

Th e regulation requires; 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 di splay 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, the words "limited," "restricted," "light

- sport," "experimental," or "provisional," as applicable. Even though the sUAS will have no airworthiness certificate, an exemption may be needed as the sUAS will have no entrance to the cabin, cockpit or pilot station on which the word "Experimental" can be placed.

Given the size of the sUAS , two

- inch lettering will be imp ossible. The word "Experimental" will be placed on the fuselage in compliance with §45.29 (f). The equivalent level of safety will be provided by having the sUAS marked on its fuselage as required by §45.29 (f) where the pilot, observer and others working with the sUAS will

see the identification of the sUAS as "Experimental." The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167 A.

14 C.F.R. § 61.113 (a) & (b): Private Pilot Privileges and Limitati ons: Pilot in

Command.

Sections 61.113 (a) & (b) limit private pilots to non

- commercial operations. Because the

sUAS is unmanned and will not carry a pilot or passenger s, the proposed operations can achieve the equivalent level of safety of current oper ations by requiring the PIC operating the aircraft to have a FAA ground school rather than a commercial pilot's license to operate this small sUAS Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled with no living thing on board. The area of operation is controlled and restricted, and all flights are planned and coordinated in advance. The level of safety provided by the requirements included herein exceed that provided by a single individual holding a com mercial pilot's certificate operating a

conventional aircraft. The risks associated with the operation of the sUAS are so diminished from the level of risk associated with commercial operations contemplated by Part 61 when drafted, t hat allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 C.F.R. §61.113 (a) & (b).14 C.F.R. §91.7(a): Civil aircraft airworthiness.

The regulation requires that no person may operate a civil aircr aft unless it is in airworthy condition. As there will be no airworthiness certificate i ssued for the aircraft,

should this exemption be granted, no FAA regulatory standard will exist for determining

airworthiness. Given the size of the aircraft and the r equirements contained herein for the use of safety check lists prior to each flight, an equivalent level of safety will be provided.

14 C.F.R. § 91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft.

Section 91.9 (b) (2) provides: No person may op erate a U.S.

- registered civil aircraft ...

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, 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.

The sUAS , given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pilot on board, but because there is no

room o r capacity to carry such an item on the aircraft.

The equivalent level of safety wil l be maintained by keeping the sUAS operation manual and appropriate checklists at the ground control point wh ere the pilot flying the

sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 95658, 10167, 10167A, 10602, 32827, and 10700.

14 C.F.R. § 91.103: Pre

-

flight action

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight ma nuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth hereinabove. Th e PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff distances and aircraft performance data before initiation of flight using appropriate checklists.

14 C.F.R. §91.109: Flight instruction:

Section 9 1.103 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 fully functioning dual controls.

sUAS and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through the use of a radio transmitter that

communicates with the aircraft via a receiver in the sUAS . The FAA has approvedexemptions for flight training without fully functional dual cont rols for a number of

aircraft and for flight instruction in experimental aircraft. See Exemption Nos.5778K &

9862A.

The equivalent level of safety provided by the fact that neither a pilot nor passengers will

be carried in the aircraft and by the size and speed of the aircraft.

14 C.F.R. §91.119: Minimum safe altitudes

Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the

perso n operating the helicopter complies with any route or altitu des prescribed for helicopters by th e FAA. This exemption is for a sUAS and the exemption requests authority to operate at altitudes up to 2 00 AGL underneath navigable airspace and in

class E and G airspace maintaining safe separation from actual aircraft, an exemption may be needed to allow such operations.

The equivalent level of safety will be achieved given the size, weight, speed of the sUAS as well as the location where it is operated. No f light will be t aken without the permission

of the property owner or local officials. Because of the advance notice to the property owner and participants in the filming activity, attempts will be made to contact all affected individuals regarding the plann ed flight operations.

Compared to flight operations with aircraft or rotorcraft weighting far more than the maximum 551bs. proposed herein, and the lack of flammable fuel, any risk associated with these operations is far less than those presently present ed with conventional aircraft.

In addition, the low

- altitude operations of the sUAS will ensure separation between these

sUAS operations and the operations of conventional aircraft that must comply with

Section 91.119.

14 C.F.R. §91.121 Altimeter Setti ngs

This regulation requires 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 avail able before departure." As th e sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exempti on may be needed.

An equivalent level of safety will be achieved by the operator, pursuant to the Manual and Safety Check list, confirming the altitude of the lau nch site shown on the GPS altitude indicator before flight.

The requirements are that altitude information be provided to the sUAS pilot via digitally

encoded telemetric data feed, which downlinks from the aircraft to a ground

- based on

screen display. Th is altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, or digitally encoded barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation poi nt will be established and confirmed for accuracy by the pilot.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 co nditions) 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 least 30 minutes; or (2) At night, to fly

after that for at least 45 minutes."

The battery powering the sUAS provides approximately between 40 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CFR §91.151, sUAV flights would be limited to approximately 10 minutes in length . Given the limitations on

the sUAS proposed flight area and the location of its proposed ope rations within predetermined area, a longer time frame for flight in daylight or night VFR conditions is

reasonable.

Petitioner believes that an exemption from 14 CFR §91.1 51 (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the sUAS in controlled area where only people and property owners or official repres entatives who have signed waivers will be allowed, with less than 30 minutes of flight operation time, does not give rise to the type of risks that Section 91.151 (a) was intended to alleviate particularly given the size and speed of the sUAS . Additional ly, limiting sUAS flights to 20 minutes would greatly reduce the utility for which the exemption will be granted.

Petitioner believes that an equivalent level of safety can be achieved by limiting flights

to 30 minutes or no less than 25 % of battery pow er, whichever happens first. This

restriction would be more than ade quate to return the sUAS to its planned landing zone from anywhere within its limited operating area. Similar exemptions have been granted to other operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 C.F.R. §91.203 (a) and (b): Carrying Civil Aircraft Certification and Registration

The regulation provides in pertinent 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 §91.71 5 is displayed at the cabin or cockpit entrance so that it is legible to

passengers or crew.

The sUAS fully loaded weighs no more than 55 lbs and typically less than 20 lbs. And is operated without an onboard pilot. As such, there is no ability or place to carry certification and registration docum ents or to display them on the sUAS.An equivalent level of safety will be achieved by keeping these documents at the ground

control point where the pilot flying the sUAS will have immediate access to the m, to the

ext ent they are applicable to the sUAS . The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 C.F.R. §91.405 (a) ; 407 (a) (1); 409 (a) (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 in compliance with Part 43.

Given that these section and Part 43 apply only to aircr aft with an airworthiness certificate, and the requirements of pre

- flight inspection required herein, these sections will not apply to the applicant. Routine and pre

- flight maintenance will be accomplished by the operator. An equivalent level of safety wi ll be achieved because these sUAS are very limited in size and will carry a very small payload and operate only in restricted areas for limited periods of time. If mechanical issues arise the sUAS can land immediately and given its small size poses very li ttle risk to persona or property. The operator will ensure that the sUAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety.

7. Publication Summary

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

Petitioner seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 45.23(b);14 C.F.R. §§ 61.113( a) & (b);91.7 (a); 91.9 (b) (2);91.103(b);91.109; 91.119; 91.121; 91.151(a);91.203(a ) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) & (b) to operate commercially a sUAV vehicle (551bs or less) for Aerial Photography & Motion Picture television Operations.

Approval of exemptions all owing commercial operations of sUAS for Aerial Photography & Motion Picture television Operations for the following; Business Operations: over land, water

- ways, and oceans; operation over/in non restricted National Parks, National Forests, flight in non

- navigable airspac e, using non

- intrusive recording devices, operation in otherwise unrestricted US States/Territories will enhance safety by reducing risk.

Conventional film operations, using jet or piston power aircraft, operate at extremely low altitudes, just feet from the subject being filmed, and in extreme proximity to people andstructures; and present the risks associated with vehicles that weigh in the neighborhood

of 4,0001bs, carrying large amounts of jet A or other fuel. In addition such actual

certificated air craft must fly to and from the film location. In contrast, a sUAS weighing fewer than 55 lbs., and powered by batteries rather than fuel, eliminates virtually all of

that risk. The sUAS is driven/carried to the film set, not flown. The sUAS will carry no

p assengers or crew and, therefore, will not expose any crew to the risks associated with manned aircraft flights.

The operation of sUAS , weighing less than 55 lbs., conducted in the strict conditions outlined above, will provide at least an equivalent le vel of safety supporting the grant of the exemptions requested herein, including exempting the Petitioner from the requirements of Part 21 and allowing commercial operations. These lightweight aircraft operate at slow speeds, close to the ground, and in a line of sight, relatively sterile environment and are, as a result, far safer than conventional operations conducted with actual aircraft/helicopters operating in close proximity to the ground and people.

8. Privacy

All business/commercial flights whic h occur over private or controlled access property will be with the property owner's prior consent and knowledge. Filming will be of people who have also consented to being filmed or otherwise have agreed to be in the area where filming will take place. P etitioner will not infringe on any individual or landowner privacy rights.

Limited nighttim e operations may be conducted. nighttime as defined FAR's in s ection is as follows 1.1. "Night means the time between the end of evening civil twilight and the

b eginning of morning civil twilight, as published in the American Air Almanac,

converted to local time.

" Night oper ations may be conducted by the sUAS following the guidelines above and provided such operations have sufficient lighting so that Petitioner/ Operator maintains visual line of sight. Allowing sUAS this exemption will provide a far safer nighttime filming alternative to the current full size aircraft operations.

9. Conclusion

The FAA's purported "ban" on bus iness/commercial Model Aircraft sU AS operations has actually had the current effect of causing American skies to be less safe. There are many actual certificated pilots who are exceptionally qualified to fly model aircraft sUAS

with their model aircraft sUAS experience, private, commercial or ATP pilot training, licenses and instructor ratings. However, these experienced operators and licensed pilots familiar with the FARs, airspace and safe operating procedures are currently reluctant to commercially operate model aircraft sUAS or be invol ved, for fear of the FAA seeking an enforcement action against them or their actual pilot's licenses.

Presently, during the pendency of these issues in the Pirker case, it defies safety or regulatory logic that according to the FAA's current alleged "ba n" on business operations

of sUAS , your average enthusiastic 12 year old, who's well meaning Father bought him a quadcopter s sUAS equipped with a camera, can operate his sUAS wherever he wants and take whatever recreational video/pictures subject only to the suggestions of FAA AC91

- 57 and yet an FAA certificated private/commerciai/ATP pilot cannot be paid to use a

far higher quality and equipped sUAS to take an aerial photo or aerially inspect a farmers

field, despite the significant improvement in sa fety over non

- pilots operating sUAS recreationally and real aircraft used for aerial photography.

Satisfaction of the criteria provided in Section 333 of the FMRA of 2012, and requiring

the sUAS PIC to have or obtain medical certificate and a actual pil ots license and considering the small size, weight, speed, operating capabilities, limited operations in proximity to airports and populated areas and operation within visual line of sight and national security

- all of which provide more than adequate just ification for the grant of the requested exemptions allowing business /comme rcial operation of applicant's sUAS for aerial photography/ motion picture/television productions as requested herein.

Ex. 1.

UdroneAir Checklists Preflight Checklists

Insp ect Vehicle 1. Check props

2. Check screws

3. Check Radio 4. Check body/arms for cracks 5. Prepare log book

6. Review mission/Check review weather 7. Check/test batteries record voltages 8. Prepare nav/gps system

9. Radio RX/TX distance test/Check timers

10. Satellite localization/lock

Narrative Descriptions.

Inspect the vehicle for previous damage like cracked chassis, loose props, motors and wires, this will ensure the safe operation of the vehicle and not a catastrophic failure of

parts.

T ighten all screws and record which ones are becoming loose over time. This will indicate problems with the vehicle structure and you should use more CA or thread locking liquid to keep this problem to a minimal. If you are repeatedly tightening the

screws in the same spot then there is a problem with the screw hole and should be tapped

or corrected.

Prepare a logbook, this will ensure that you are recording the proper flight times and will indicate battery health, saving you from a failure and possible lo ss of vehicle. Pull out thedocument you use for logging your flight fill out the information that is most important:

date, time, and mission information.

Weather affects the performance of a vehicle and should be calculated to ensure proper weights given to your flight and battery time totals. Weather inf ormation to include as

follows: Temperature, wind speed, maximum gusts, ambient temperature, humidity, dew point, barometric pressure, and any solar information that can effect your GPS. Review

your mission so that you know exactly what you plan to do and what data you will gather.

Check and test your batteries so that you have sufficient power for your mission. If you followed this checklist your batteries should have been charged the last time yo u put your vehicle away. Turn on the navigation system if applicable and verify the appropriate settings to localize the satellite signal. Check for solar flare information and gps outages in your area connected to your mission.

II. Before Flight

1. Turn on transmitter; Check set flight mode

2. Set throttle down 3. Clear flight area 4. Connect battery on the vehicle

5. Start motors 6. Verify indicator lights for proper indications/GPS locks 7. Throttle up slowly 8. Maintain visual separation fr om all obstructions

Narrative Descriptions:

You should always be near your transmitter so that in the case of a failure you can control the vehicle to the best of your abilities and get the vehicle safely to the ground. First turn the transmitter on, with the throttle turned all the way down.

Next walk over to the vehicle that you plan to fly clear area and connect the battery. You should connect the battery in a way that does not disturb the vehicle from sitting on the ground, when you plug the vehi cle up it is calibrating the flight system and powering up safely.

When the lights give proper indications it is safe to either pick up the vehicle safely and move it or walk away from it with your controller in your hand. To begin your flight

move the s ticks up slowly until the vehicle leaves the ground maintain visual separations from people, bu ildings, obstructions, other UAS /aircraft.Ill. Post Flight/After Landing

1. Unplug battery on vehicle while near the controller 2. After battery is unplugged turn off the controller 3. Fill out log books

Narrative Descriptions:

Once the vehicle has returned to the ground, walk over with your controller and disconnect the wire to the vehicle battery, this will essentially kill the power and rend er the vehicle in the safe to transport mode.

Next you can power the controller off to save the battery life. Return the vehicle to a safe place and then locate your logbooks and recover your data.

IV. Debrief

1. Fill out logs 2. Complete calculati ons for batteries and flight times 3. Put away gear, vehicle and log books

Our Aircraft: Cheerson CX20 with autopathfinder GPS