**Michael Wing**

**Meridian UAS CEO**  **940 SE Bell Av. Corvallis, OR 97333**  **Telephone: 541.738.2772**  **Em ail:**  **michaelwing01 @** **gmail.com**

October 22, 2015 U.S. Department of Transportation Docket Management System West Building Ground Floor Room w12

-140 1200 New Jersey Avenue, SE Washington DC 20590
**RE: Exemption**  **Request Section**  **333 of the**  **FAA Reform**  **Act**
Dear Sir or Madam:
We respectfully request exemption under Section 333 of the FAA Reform ACT and Part 11 of the Federal Aviation Regulations. **Petitioner: Michael Wing**  **Meridian UAS CEO**  **940 SE Bell Av. Corvallis, OR 97333**  **Telephone: 541.738.2772**  **Em ail: michaelwing01** **@gmail.com** Meridian UAS is a LLC

. Meridian UAS intends to incorporate the use of sUASs for a variety of projects which may include but not be limited to project and construction management, inspections and monitoring; environmental review projects; aerial surveying; agricultural projects; educational and research projects; remote sensing projects, wildlife and forestry monitoring projects; aerial filmmaking, photography and real estate purposes; search and rescue, etc. **Proposed Operations**  Meridian UAS proposes to use the following platforms in seeking an Exemption Pursuant to Section 333: Aerialtronics Altura Zenith (ATX8 and STR8), DJI Phantom 2 Vision, DJI Phantom 3, and 3DR Solo.**Previous FAA Exemptions**

Each of the platforms proposed in this Exemption request have been granted previous Exemptions Pursuant to Section 333 by the FAA based on the platform weight, speed, and operational characteristics: **Aerialtronics Altura Zenith ATX8, STR8**: Exemption 12655 to Jonathan Adams **DJI Phantom 2 Vision+**: Exemption No. 11228 to Steven Zeets **DJI Phantom 3**: Exemption No. 13203 to Matthew D. Gambill **3DR Solo:** Exemption No. 11935 to Patricia A. Lines In granting these previous Exemptions, the FAA has found that each of these platforms shared the following characteristics:
 Weight is less than 55 pounds including payload.
 The ability of the UAS to operate safely after experiencing in

-flight contingencies or failures, and the presence of an auto

-pilot to maintain flight stability and control . The UAS is also able to respond to a loss of GPS or a lost

-link event with a pre

-coordinated, predictable, automated flight maneuver. These safety features provide an equivalent level of safety compared to a manned aircraft performing a similar operation and mitigate the risk of command and control link failures.
 Communication and control radio frequencies comply with the Federal Communications Commission (FCC) and other appropriate government oversight agency requirements.
 The maximum speed of the platforms is 87 knots or less.
**Public Benefit** Meridian UAS conducts research in a variety of disciplines. Public benefit of the UAS operations proposed in this Exemption request includes the following societal benefits:
 Worker safety is emphasized as UAS operations can reduce or eliminate field measurements. There are significant risks to workers in the construction and structural inspection industries that can be alleviated by UAS.
 Manned flights pose risks to pilots.
 Greater image resolution can be obtai ned from UAS mounted sensors in comparison to manned aircraft as UAS are able to fly slower and closer to the ground. Increased image resolution allows for more robust analysis which can lead to increases in agricultural and forest productivity.
 Search and rescue operations can be conducted in areas that might be ordinarily be inaccessible.
 UAS are more cost effective than manned aerial platforms.

**Reasons why**  **the exemption**  **would not**  **adversely affect**  **safety or**  **how the**  **exemption would**  **provide a**  **level of**  **saf ety**  **at least**  **equal to**  **the existing**  **rules.** 1. The UAS platforms weigh less than 20 pounds, including payload; 2. Flights will be operated within the visual line of sight of the pilot; 3. Maximum total flight time for each operational flight will be (45) minutes. Flighttimes may be less than thirty (30) minutes as the UAS will continuously monitor

battery reserve and return to the ground station with at least 10% battery power reserved; 4. Flights will be operated at an altitude not greater than 4 00 feet AGL; 5. Minimum crew for each operation will consist of the UAS pilot and a Visual Observer; 6. A briefing will be conducted daily by all personnel working with said UAS; 7. Written and/or oral permission from relative property owners will be obtained prior to operating the UAS; 8. All permits, permissions, etc. will be obtained from local government offices as required; 9. The UAS will operate at speeds less than 8 7 knots, hover and simultaneously move vertically and horizontally; 10. The UAS will have the capability to return and land at the pre-determined location with the Security Perimeter should the UAS lose communication or GPS signal during any operations; 11. The UAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies; 12. Operations will not be conducted over densely populated areas or heavily traffic highways; and 13. Operations will not be conducted within five (5) NM of an airport or heliport without permission of the airport or heliport.
**Exemptions Sought from CFRs** Meridian UAS requests Exemptions from the following CFRs: 1. 91.9(b)(2), 91.203(a) and (b): Carrying Aircraft Flight Manual, Certification and Registration in the Aircraft Given the small size of the proposed UAS platforms, OSU requests that these materials be kept in the vicinity of the ground control station during flight. 2. 91.7(a): Civil Aircraft Airworthiness Meridian UAS requests that no Airworthiness Certificate be required. 3. 91.9(c), 45.23(b), and 45.27(a): Aircraft Marking and Identification Requirements Meridian UAS requests that proposed platforms bear registration numbers that are as large as practical in accordance with platform size. 4. 61.23(a) and (c), 61.113, 61.101(e)(4) and (5), 61.315: Private, Recreational and Sport Pilot Medical Certificate, Privileges and Limitations Meridian UAS seeks an exemption from these CFRs as they prevent private, recreational or sport pilotcertificate holders from receiving pay for piloting duties. The UAS platforms in this petition will not carry

passengers or cargo, and the FAA has previously ruled (Exemption No. 11062) that a Commercial Pilot Certificate is not required for UAS operations outside of controlled airspace. 5. 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2); 91.417(a) and (b): Maintenance Inspections Meridian UAS seeks exemptions to these CFRs as they are intended for aircraft that have an airworthiness certificate. Meridian UAS will ensure that all UAS platforms and components have an adequate maintenance and inspection schedule. 6. 91.121: Altimeter Settings Meridian UAS seeks an exemption from the requirement that a pilot maintains a flight level through reference to an altimeter. The FAA has previously stated that equivalent functionality can be achieved when flights occur at or below 400 feet AGL and when GPS elevation data can be transmitted in real time to a ground control station, given that a PIC establishes GPS elevation accuracy on

-the

-ground prior to every flight. 7. 91.151(a): Fuel Requirements for Flight in VFR Conditions Meridian UAS seeks an exemption from the requirement that fuel reserves during VFR require that no less than 30 minutes of fuel be maintained during the day and 45 min utes during the night. Given that the platforms in this petition generally have a 30 minute or less flight time, no meaningful flights would occur under 91.151(a). Exemption No. 11213 determined that an equivalent level of safety is evident in UAS flights where the operational flight time can be achieved with an additional five minutes of flight time being available in fuel reserves.

Please feel free to contact our office should you have any additional questions or comments. Thank you for your cooperation with this matter. Sincerely, Michael Wing