4125 Centurion Way, Suite 100 ▪ Addison, TX 75001 ▪ (972) 408

- 3601



## Request for Section 333 Exemption

– Utilities

September 29 , 2014

CONFIDENTIALITY NOTICE: This document and any files attached to it may contain information that is proprietary, confidential and/or exempt from disclosure under applicable law. It is the property of Aviation Unmanned and/or its affiliates and is intended solely for the use of the individual or entity to it is addressed. If you are not the intended recipient, you are hereby notified that any use, retention, disclosure, forwarding , printing, distribution or copying of this
information is STRICTLY PROHIBITED.2

September 2 9 , 2014

The following letter constitutes an e xemption Request under Section 333 of the FAA
Modernization and Reform Act of 2012 for Aviation Unmanned to perform Utility inspections
for Center Point Energy

. The UAS systems that we will use and will be referenced in this document are the Vanguard Defense Industries ShadowHawk and the MLB Comp any Super Bat.

Point of Contact: Address: Eric Fay 4125 Centurion Way, Suite 100 Mobile: (702) 544

- 7371 Addison, Texas 75001 Direct: (972) 360

- 3121 Eric@AviationUnmanned.com

1. Specific sections of 14 CFR from which we seek exemptions.

a) §61.3(a)(1): Requirement for certificates, ratings, and authorizations

a. There are no ratings for UAS operators as of yet, so we would like to use our

current FAA commercial certificates in lieu of the lack of UAS certificates. b) §61.13: Issuance of airman certificates, ratings, and authorizations c) §91.7 : Civil aircraft airworthiness

. No person may operate a civil aircraft unless it is an airworthy condition

a. There are no certifications for the airworthiness of UAS to date, so we are looking to rely on our field maintenance training and schedule to ensure our aircraft are in an airworthy condition before all flights. d) §91.113 : Right of Way rules (see and avoid)

a. We will have observers out during flights, and to the maximum extent possible stay below 400’ AGL and away from controlled airspace. e) §91.203(a)(1) & §91.203(a)(2) : Civil Aircraft: Certifications Required f) §91.205(b) : Powered civil aircraft with standard category U.S. airworthiness certificates:
Instrument and equipment requirements

a. Specifically items (5) and (7) through (17). We do not plan to fly at night initially. g) §91.207 : Emergency locator transmitters h) §91.125 : ATC transponder and altitude reporting equipment and use

a. We do not currently have transponders on our aircraft but could install them if

necessary. i) §91.319 : Aircraft having experimental certificates: Operating limitations Specifically §91.319(e)3

2. E xtent of relief we seek and the reason we seek the relief

The request for these exemptions is for the use of our Unmanned Systems to provide utility companies with power line inspections in areas outside of Houston TX . These inspections
would include right of way surveying, tow er inspections for early detection of arcing , and post

disaster aerial support. We are working with Center Point Energy, one of Texas’ largest utility corporations, to provide these services across their 5,000 square mile s of energy lines west and north of Houston, TX (see Figure 1)

. Cen ter Point is interested in the ability of UAS to investigate remote and/o r inaccessible areas of power lines safely, as well as provide early
identification of power interruptions and provide real time data to direct their personnel

accura tely in the event of a natural disaster

.

3. How our request would benefit the public as a whole

Routine Inspections

With the routine inspection of power lines (distribution or transmission), our Corona cameras can identify arcing early which will allow Center Point Energy to repair the affected area before they become a problem. This early identification will help Cent er Point maintain constant service to their customers, and allow the residents of Houston and the surrounding areas to keep their houses powered. Center Point has identified a need for this early detection in order to ensure their customers do not experie nce power interruptions. Figure 1: Requested area around Houston, TX4

Emergency Response

After Hurricane Ike in 2008, much of Houston and Galveston was without power for over 10 days. Center Point has learned many les sons from this event, one of which was that they didn’t have accurate, real ti me information. They were sending tho usands of personnel and trucks

out to survey and repair areas that turned out to be not badly damaged, while other heavily damaged areas heavily were left undiscovered for days. In the event of another disaster such

a s this, or even one on a small er scale, we would like to use our Unmanned Aircraft to assist Center Point with identifying the true problem areas which will allow them to focus their repair efforts accurately and significantly decrease the time to get powe r restored

.

4. Reasons why the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to the existing rule

T he majority of areas to be covered are remote, sparsely populated, and we thoroughly m ission plan before each flight. We check current sectional charts for airspace restrictions, NOTAMS, TFR’s, restricted airspace, and helicopter corridor charts. Our aircraft will be flown to the maximum extent possible below 400’ AGL, outside of any cont rolled airspace and outside of 3 miles from any airport IAW §91.126(d), but at all times at a minimum safe altitude to allow for obstacle and terrain clearance. Should we need to fly closer than three miles from an airport
we will establish and maintain r adio communications wit h the controlling agency at any applicable airfields.

We have a robust safety observer program, and if required our aircraft can be monitored by Aviation Unmanned personnel who at a minimum possess FAA ground school certificates. O ur safety observes have also undergone training and maintain constant two way radio
communication with the PIC.

5. Summary to publish in the Federal Register

Aviation Unmanned seeks an exemption from regulations of 14 CFR to perform regular and emergency inspection services with Unmanned Aircraft on power lines. These inspections would take place in remote areas of South East Texas and the Louisiana Gulf Coast region.

6. Additional information, views, or arguments available to support our request

We have established standard op erating procedures within our company to enable safe and effective use of our unmanned systems in any situation. Our operations and these standards are based on our extensive military flying experience in the MQ

- 1B and MQ

- 9 systems for nearly 18 years com bined, and we comply with 14 CFR to the maximum extent possible. Furthermore, our operations are safe, efficient, and will ultimately show the public and FAA that operating UAS with the correct skillset is safe for commercial use.5

Certifications and Trai ning

 Our pilots all hold current FAA Commercial Pilot certificates and a minimum of FAA
Second Class medicals.

 Many of our pilots hold CFI, MEI, and ATP certificates as well as current m ilitary qualifications on unmanned aircraft

.

 Our pilots have completed rigorous training for the systems we operate including
academic s , simulator s , and flight training . These courses , developed by Aviation Unmanned in conjunction with manufacturer s, provide our pilots the best training possible to operate our systems . Thi s also includes emergency procedure training and evaluation, experience building with a qualified instructor, and initial/recurring flight
evaluations.

Currency and Proficiency

 Our pilots maintain currency and proficiency in accordance with a company spec ific Aircrew Proficiency Program. If crewmembers lapse on currency, they are not able to perform flying duties until completion of either (depending on how long they have been

non

- current): at least one flight with a qualified instructor or re

- training an d completion of a flight review by a qualified instructor.

Flight Operations

 Each flight is o perated under the crew concept, and t here are always two ful ly qualified pilots in the crew. The Pilot in Command is responsible for fly ing the aircraft and

ensu ring the safety of flight operations, the Second in Command is responsible for operating the payload and providing input to the PIC . In the event of PIC incapacitation the SIC can step in and safely land the aircraft.

 We abide by a “sterile cockpit” rul e anytime one of the following three criteria are met:

 Presets or Landing checklists have started

 Altitude is less than 15 0’ AGL or

 Aircraft position is 0.25 nm or less from the ground control station.

Regulations Adherence

 Our crews are required to adhere to 14 CFR §91.17 (Alcohol or Drugs) and 14 CFR §121.471 (Flight time limitations and rest requirements: All flight crewmembers)

Aircraft

 The system s we will use to perform these inspections are proven, reliable systems.

 Our aircraft have detaile d L ost Comm plans that, in the event of a loss of communication, will bring the aircraft back at a specific altitude, position, and airspeed.

 We can set them to automatically land in a cleared area or hover over the
cleared area while we work to get the com munications back.

 We always set the L ost C omm plan routing to avoid populated areas and major
roads6

7. Reasons why you want to exercise the privileges of our exemption outside the United States

We do not currently intend on exercising these privileges out of the United States.

Please feel free to contact me if there are any questions or issues regarding this request.

Eric Fay, President/COO
Aviation Unmanned