July 30, 2015

Nathan Rea Owner/Operator Squadron Optics LLC 3220 Honey Locust Dr. Loveland, CO 80538 (970)685

- 7602 squadronoptics@gmail.com
Request s exemption from multiple regulatory provisions to allow the use of small unmanned aerial systems on land , controlled by clients of Squadron Optics LLC, to assist in the safe evaluation of infrastructure and property for our clients

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Squadron Optics LLC respectfully requests an exemption from several provisions o f Title 14 of the Code of Federal Regulations (C.F.R.) , to permit the use of small unmanned aerial systems (sUAS) to assist in the evaluation and documentation of infrastructure and property for our clients. This request is motivated primarily by the desi re to maximize safety in inspection operations. I t would allow Squadron Optics LLC, t o broadly evaluate a ssets and property with sUAS, resulting in a safer and more efficient work environ ment . Accordingly, the grant of an exemption is consistent with Cong ress’ intent, reflected in Section 333 of the FAA Modernization and Reform Act of 2012 (Modernization Act) 1
, that safe systems be permitted in the national airspace prior to the issuance of final regulations governing general use of these systems. 2 A summ ary of this request suitable for publication in the Federal Register is provided as Appendix A. Appendix B provides the manufacturer’ s information regarding : the design, aircraft performance, and fail

- safe features. We have provided manufacturer informat ion related to : operating limitations, normal and emergency procedures, and maintenance and inspection procedures. As we add aircraft designs, we will update this appendix appropriately.

1 P.L. 112

- 95, 126 Stat 11, February 14, 2012

2 Section 333(b)(2) specifically contemplates that the FAA may issue a certificate of waiver upon a finding that a type of UAS, as a result of its size, weight, speed, operational capacity, prox imity to airports and populated areas, and operations within visual line of sight do not create a hazard to users of the NAS or the public or pose a threat to national security.**Background Information**

Squadron Optics LLC is an up and comi ng company in Northern Colorado that specializes in the safe operation of sUAS. Our clients look to Squadron Optics LLC for us to be the sUAS experts , and to fly them in the safest possible way. We have developed our SOP s and work environment to reflect and promote safe sUAS operations. **Infrastructure Safety Inspection Operations:** Utility Inspection Agriculture Inspections Oil

- Field Inspections Pipeline Inspections Railroad Inspections Construction site Inspections Real Estate Inspections Sit e Planning Aerial assessments As part of this , Squadron Optics LLC is also requesting FAA Exemption for sUAS operations for safety inspections and video capture usage. **Regulatory Basis for Exemption Request** In addition to the waiver authority provided i n §333 of the Modernization Act, the FAA may grant an exemption under 49 U.S.C. §44701(f) , if it has determined that such an exemption is in the public interest. The FAA has imposed a separate requirement in its procedural regulations, providing that the petitioner shall explain why granting the exemption would not adversely affect safety, or how the exemption would provide a t least an equivalent level of safety as compliance with the underlying regulation. In this case, approval of this exemption would a dvance the public interest by significantly enhancing the safety and efficiency of infrastructure operations , and by providing the FAA with valuable user experience on sUAS in a context with appreciable economic and societal benefits. As described more fu lly below, the requested exemption would permit the operation of sUAS under tightly controlled conditions, thus ensuring that operations will not have an adverse impact on safety. To the contrary, the use of large aircraft with fuels and personnel are at a greater safety risk than the use of sUAS. Granting an Exem ption is in the public interest because t he safety and efficiency of inspection operations is heavily dependent u pon constant analysis of: right

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-way, inspection , and other assets/facilities. Even relatively small objects , or minor failures , can lead to accidents or other incidents causing downtime of infrastructure. Extreme weather events can lead to flooding, or overheating infrastructure. For example : tor nados, floods, landslides, wild lan d fires, and abandoned vehicles at grade crossings , can block infrastructure. The potential for trespassing is also among the many risks that modern infrastructure faces. As a result, pursuant to federal regulations and company policy, our client’s maint enance employees routinely inspect the infrastructure, such as : bridges, tunnels, support structures, and signals. At present, this work is done primarily by company personnel in motor vehicles, on foot, or in specialized equipment. This is often a labor

- intensive and sometimes arduous job. While our clients do all they can to make these inspections as safe as possible, there is an irreducible element of risk involved whenever employees are required to go out on structures. Employees may need to climb ov er or onto structures, which can be slippery, rough, and/or exposed to the elements. Some structures, such as bridges, arehigh above the ground. Equipment moving through inspection zones can increase risk as well, especially

in high

-traffic areas. Whil e the use of sUAS for supplemental infrastructure and general asset evaluation would not eliminate these risks entirely (as it is an additive safety measure), it would reduce the risk to employees by allowing for remote aerial review. Additionally, the sheer amount of assets and the widely dispersed locations

– in many instances far from sizeable population centers

- means that visual inspection in all instances by company personnel can be inefficient. Aerial analysis by traditional fixed wing aircraft , is impractical because the required altitudes for safe flight reduce visi bility below meaningful levels; it is simply not possible to see all asset anomalies from such heights. Helicopter s present better vantage points. H owever, manned helicopters are mu ch more costly, subject to human safety and carry highly explosive jet fuel , making them impractical for deployment. By using sUAS for supplemental asset evaluation, Squadron Optics LLC will be able to substantially upgrade its capacity to detect and addr ess issues with the right

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- way and other assets , before they become a problem for safe operations. Thus, the use of sUAS has the potential to improve efficiency, resulting in faster and s afer delivery of goods, energy, and natural resources vital to the U.S. economy. **Granting an Exemption will not adversely**  **affect Safety**  Squadron Optics LLC notes that there is no applicable standard for an equivalency determination. Some have argued that the appropriate standard is that for model aircraft, noting that their operations, if conducted for recreational purposes, would fall completely within the allowable operations for model aircraft. We believe it makes more sense to focus on why the contemplated operations would not adversely affect safety, which is all t hat §11.81(e) requires. Granting an exemption will not adversely affect safety. Squadron Optics LLC contemplates conducting sUAS operations over client owned or controlled land, solely during daylight hours, at altitude well below that which would pose r isk to other aircraft s . In general , sUAS operations are intended to be conducted in areas distant from both congested areas and airports. Moreover, because of the inherent risks presented by standard infrastructure operations, our clients have already ta ken steps to secure property against unauthorized public access. For example, agricultural farms, railroad track, and pipeline are elevated, fenced or otherwise secure from unauthorized access. Other long stretches of track and pipeline are in such remot e parts of the wilderness that interaction with people is unlikely. The nature of operations anticipated by Squadron Optics LLC requires that the sUAS be flown at low speeds and low altitudes. Squadron Optics LLC expects that in most instances, the sUAS will be flown less than 75ft from the highest structure along the path of the sUAS. Accordin gly, the risk of interference with another aircraft is minimal. Additionally, Squadron Optics LLC has also worked out agreements with local airports. If a flight is within the 5 mile radius of the airport, a flight plan will be submitted to the director of operations for approval before fli ghts will take place. Squadron Optics LLC will comply with any directions issued by air traffic control at the airport.
Ap proval of exemption , allowing commercial operations of sUAS in the infrastructure and agricultural aerial inspection industry, will enhance safety by reducing risk. Conventional operations, using jet or piston power aircraft, operating at extremely low al titudes , just feet from the subject being inspected , and in extreme proximi ty to people and structures present a risk associated with vehicles that weigh in the neighborhood of 4,000lbs and carrying large amounts of jet A or other fuel (1 40 gallons for jet helicopters); s uch aircraft s must fly to and from the inspection site. In contrast, a sUAS weighing fewer than 55lbs and powered by batteries eliminates virtually all of that risk, given the reduced mass and lack of combustible fuel carried on board. Th e sUAS is carried to the inspection site. The sUAS will carry nopassengers or crew and, therefore, will not expose them to the risks associated with manned aircraft

flights. The operation of sUAS, weighing less than 55lbs, conducted in the strict cond itions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including : 333 Aircraft Exemption Status , exempting the applicant from conventional aircraft requirements , and allowing commercial op erations. These lightweight aircraft s, operate at slow speeds, close to the ground, and in a controlled environment. As a result, they are far safer than conventional operations co nducted with turbine helicopter operation s, in close proximity to the groun d and people. The safety of those on the ground , is protected by the fact that no one will be allowed in the area , without the permission of the company and pilot in charge (PIC). Security will be established for the flight area as part of the pre

-flig ht control. Each individual , within the secure area , will be briefed prior to flight and will consent to being in the area. All others will be excluded from the area. Squadron Optics LLC initially intends to use a dedicated staff for sUAS operations. A ll operations will be within visual line

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- sight (i.e. no more than  ̃0.5 miles from the PIC). Each PIC will conduct at least three take

- offs and landings with sUAS, on which he or she is trained every ninety (90) days. PICs will est ablish their qualific ations threw a combination of : aeronautical knowledge, sUAS airmanship skills, and verification , threw testing of flight ability before infrastru cture operations have commenced; Depending on the type of operation. Additional ground

- based visual observe rs m ay be employed as well. These observers will be within constant visual line

- of

- sight, and in constant contact with the PIC. The visual observers will assist the PIC in avoiding objects near the sUAS.
There are no standards for either Private or Commerci al sUAS pilot certificates. The safe operation and control of the sUAS, as described in this application , does not depend on the type of FAA license held by the PIC. Given the restricted and controlled airspace within which operations will take place, th e key factors nee ded by the PIC are : knowledge of the airspace within which the operation will take place , how that airspace within which the operation will take place , and how that airspace fits into the National Airspace System (NAS). That knowledge can be , and is gained primarily through , ground school and not through flight training in fixed wing or rotor aircraft. N or is it dependent on the acquisition of the factors and skills needed for the safe operation of those types of aircraft (fixed wing or r otorcraft). It cannot be assumed that a commercial pilot, approved to operate a helicopter of fixed wing aircraft , has the skill or ability to safely operate a sUAS, operating at 400AGL or lower, within strictly controlled pre

approved airspace. Besides knowledge of airspace regulations, dexterity in the control and operation of the sUAS, acquired from actual operation of the aircraft , is the most important factor in establishing an equivalent level of safety. If the PIC has acquired the necessary knowl edge of airspace requirements, the relevant issues are : one (1) where the aircraft will be flown, two (2) the size of the aircraft relative to what is being used today to accomplish the same mission, and three (3) what precautions will be taken to ensure t he safety of those in the area of operation. We propose that the PIC has at least an FAA 3 rd class medical certificate , and a working knowledge of the NAS. The aircraft will be operated within a secure environment; and that no one be allowed to enter the secure environment unless they are part of the operation, have been fully briefed of the risks prior to operation of the sUAS, and have consented to the risks associated with being in the operating area. Should there be a mishap, the sUAS being flown wil l pose significantly less of a threat than the helicopters and fixed wing aircraft now being employed , because : they are a fraction of the size, carry no flammable fuel, do not carry crew or passengers, and pose an infinitesimal risk toothers. This is in stark contrast to conventional aircraft s that are : flown to the site, carry, explosive fuel,

carry passengers and crew, and operate in a much larger area. From a practical standpoint, there are relatively few licensed full

- scale aircraft pilots , who ar e also qualified to fly the type of sUAS that are utilized for infrastructure image

- capture operations. There are even fewer commercial pilots that can fly these sUAS

– to the point that to do both is considered rare. Assuming that it is unlikely for a c ompany to find a pilot that has both qualifications, the company would either have to source a qualified sUAS pilot to train and obtain a commercial certificate, or find a commercial certified pilot who would be willing to learn to fly a sUAS to the compet ency level required for professional use. Minimum Requirements for PIC include: 1) 3 rd Class Medical certificate 2) A minimum of 200 flight cycles and 25 hours of total time as a sUAS rotorcraft pilot and at least 10 hours logged as a sUAS pilot with a simila r sUAS type. 3) A minimum of 5 hours as sUAS pilot with the make and model of sUAS to be utilized for operations under the exemption and 3 take offs and landings in the preceding 90 days. 4) Have undergone a qualification process as specified in the Standard O perating Procedures consisting of a knowledge & skills test of the aircraft to be used. Another consideration supporting the certificate requirement, is that pilots operating sUAS will all pass a Colorado Bureau of Investigation background investigation . This requirement should ameliorate security concerns over sUAS operations under this exemption. Squadron Optics LLC intends to use commercially available sUAS components for sUAS. These sUAS syst ems will be tested for quality and safety in our mainte nance shop before being deployed to the field. The sUAS is less than 55lbs , fully loaded, carries neither a pilot nor passenger, and operates exclusively within a secured area. We will maintain logs of all flights to verify that the sUAS will remain in s afe and operational conditions. Please see **Appendix B** , for specific types of sUAS. Notes Regarding: 14 C.F.R. Part 21 Subpart H In accordance with the statutory criteria provided in Section 333 of PL 112

- 95 in reference to 49 USC 44704, and in consider ation of the size, weight, speed, and limited operating area associated with the aircraft and its operations , we request that this aircraft exemption meet the conditions of section 333. Therefore, if granted Section 333 relief of 14 CFR part 21, and any a ssociated noise certification and testing requirements of part 36, is not necessary

. Notes Regarding: 14 C.F.R . §45.23 (b) Marking of the Aircraft Given the size of the sUAS, two

– inch lettering will be impossible. sUAS will be identified by ser i al n umber, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Marking will be as large as practicable. Notes Regarding: 14 C.F.R. §91.7 (a) Civil Aircraft Airworthines s Squadron Optics LLC is based on the fact that no airworthiness certificate will be issued for sUAS. Squadron Optics LLC will not require an airworthiness certificate in accordance with 14 C.F.R. part 21, subpart H. Based on the fact that an airworthin ess certificate will not be issued, exemption from § 91.7 (a) is not necessary.Notes Regarding: 14 C.F.R. § 91.9(b)(2) Civil aircraft flight manual, marking, and placard

Certifications required: T he original intent of these regulations was to display a n aircraft’s airworthiness, certification, and registration documents so they would be easily available to inspectors and passengers. Based on the FAA Memorandum subject “interpretation regarding whether certain required documents may be kept at an unma nn ed aircrafts control station,” dated August 8, 2014, the requested relief from §14 C.F.R. 91.9(b ) ( 2) and §91.203(a) and (b) is not necessary. Notes Regarding: 14 C.F.R. § 1.109 Flight ins truction; Simulated instrument, and certain flight tests Small sUASs , by their design, do not have fully functional dual controls. Flight control is accomplished through the use of a control box that communicates with the aircraft via radio or wireless fidelity (WiFi) communication. Aircraft s, being considered for use by S quadron Optics LLC, allow the sUAS Instructor to place the aircraft into ‘LTR ’ or loiter mode (fixed altitude stationary hold). In the event of the student losing contr ol, the sUAS Instructor is trained to put the sUAS in to ‘LTR mode’ in a quick and safe manner. The instructor will then take command of the sUAS and bring it back to a safe pre

- determined location. Squadron Optics LLC does not describe training scenarios in which a dual set of controls would be utilized or required, i.e. dual flight instru ction, provided by a flight instructor or other company

designated individual, which would require that individual to have fully functioning dual controls. Rather, Squadron Optics LLC evaluates the qualification of its PICs based on their experience with the sUAS to be operated and verifies through testing, in lieu of their experience with the sUAS to be operated and verifies through testing, in lieu of formalized training. As such, Squadron Optics LLC does not seek relief from 14 C.F.R. § 91.109.

Notes Regarding: 14 C.F.R. §91.119(b) Relief from 14 C.F.R. § 91.119(b), operation over congested areas , is not applicable because Squadron Optics LLC operations will only be conducted within the secured area described herein. **Squadron Optics LLC Safety Opera tions & Procedures Overview:**  Technology Considerations: Best

- in

- class, tried and proven technologies that are in advanced iterations. Software from highly

reputable industry leaders will include features

– 1. Auto descent (landing) if communication signal were to be severed. If the sUAS loses communications, the sUAS will have capability to return to a pre

- determined location within the Security Perimeter and land. This is known as ‘RTL’ or Return

-to

- launch. 2. Auto descent (landing) if battery were to dr op lower than nominal level. 3. Flights will be terminated at 25% battery power reserve. 4. Live video for operator gives real

-time positioning feedback. In other words, we can monitor the scene from the vehicles perspective for collision avoidance, and to ma intain spatial orientation. 5. The sUAS will have the capability to abort a flight in case of unpredicted obstacles or emergencies. 6. O n - screen - displays (OSD) contain operating information to a certain vehicle health at all times: speed, altitude, number o f GPS satellites (when available), heading and voltage. 7. GPS lock supplies for return

-to

- launch (RTL ). Should Command and Control link failures occur (highly improbable), vehicle returns automatically to the point of launch. 8. Altitude information will be provided to the sUAS pilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground

- based on

- screen display. Thisaltitude information will be generated by equipment installed on board the aircraft, using GP S triangulati on, digitally encoded barometric altimeter, or radio altimeter, or a combination thereof. Prior to each flight, a zero altitude initiation will be established and confirmed for accuracy by the pilot. Mechanical/Physical: 1. We will fly line

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- sigh t (LOS) only. The vehicle will always remain in direct LOS to the pilot, thus eliminating the concern of signal severance (flying behind objects/walls) 2. The sUAS will weigh less than 55lbs and travel at less than 50 knots (57 mph). 3. Batteries should far exceed the capacity required for actual flight time. 4. Flights will be operated at an altitude of no more than 400 feet AGL. 5. Fireproof bags for storage and charging of high capacity Lipo batteries on

- site. 6. sUAS operated under this exemption will be marke d in accordan ce with 14 C.F.R. p art 45 or otherwise authorized by the FAA. Personnel: 1. Spotters ensure safe operation and act as a redundant set of eyes for operators (pilot, gimbal op, director) 2. Radio spectrum analysis for interference on the frequencies utilized for vehicle control/communication. 3. A briefing will be conducted in regard to the planned sUAS operations prior to each day’s activities. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety perimeter b e present for this briefing. 4. The operator will obtain the consent of all persons involved in the sUAS operations and ensure that only consenting persons will be allowed within 100 feet of the flight operations. 5. Observer and pilot will at all times be a ble to communicate by voice or radio

. 6. Written and/or oral permission from the relevant property holders will be obtained. 7. Pilot and observer will have been trained in operation of sUAS generally and received up -to

date information on the particular sUAS to be operated. 8. Squadron Optics LLC will be CPR and first responder qualified for the unlikely event a mishap happens. Operations: 1. The unmanned aircraft (UA) must weigh less than 55 pounds (25Kg), including energy source(s), and equipment. Operations au thorized by this petition of exemption are limited to the following aircraft described in Appendix B. Proposed operations of any other aircraft will require a new petition or a petition amendment to this request. 2. The US may not be flown at ground speeds exceeding 50 knots. 3. Flights must 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 altitude reported to ATC must be in feet AGL. 4. The US must be operated wit hin visual line of sight (LOS) of the PIC at all times. 5. All operations will utilize a visual observer (VO). This roll can be fill by a second person or by the PIC during an autonomous mission. 6. The operator’s manual included in Appendix B and this peti tion of exemption must be maintained and made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operator’s manual, the conditions and limitations herein take precedence and must be followed. Otherwise, the operator must follow the procedures as outlined in its operator’s manual.The operator may update or revise its operator’s manual. It is the operator’s responsibility to track such revisions , and present updated and revised documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment. If the operator determines that any update or revision would affect the basis for which the FAA grants this petition for exemption, then the operator must petition for an amendment to their exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operator’s manua l. 7. Prior to each flight , the PIC must inspect the UAS to ensure it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary mai ntenance has been performed , and the UAS is found to be in a condition for safe flight. The Ground Control Station, if utilized, must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft recor ds. 8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight in accordance with the operator’s manual. The PIC, who conducts the functional test flight , must make an entry in the UAS aircraft 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. The operator mus t follow the manufa cturer’s UAS aircraft/component: maintenance, overhaul, replacement, inspection, and life limit requirements. When unavailable, aircraft maintenance/component/overhaul, replacement, and inspection/maintenance requirements must be establi shed and identified in the operator’s manual. At a minimum, requirements for the following must be included in the operator’s manual: a. Actuators/Servos; b. Transmission (single rotor); c. Power plant (motors); d. Propellers; e. Electronic speed controlle r; f. Batteries; g. Mechanical dynamic components (single rotor); h. Remote command and control; i. Ground control station (if used); and j. Any other components as determined by the operator. Any 2m micro/miniature repair maintenance that is conducted on the sUAS will be in accordanc e with aviation standards. 10. The Pilot In Command (PIC) must possess , at least, a current third

- class medical certificate. 11. Prior to operations conducted for the purpose of infrastructure inspections, the PIC must hav e accumulated and logged, in a manner consistent with 14 CFR § 61.51(b) , a minimum of 200 flight cycles and 25 hours of total time as a UAS rotorcraft pilot and at least 10 hours logged as a UAS pilot with a similar UAS type (single blade or multirotor). P rior 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 petition of exemption to accomplish the req uired flight cycles and flight time. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered non participants, and the PIC must operate the UA with appropriate distance from nonparticipan ts in accordance with 14 CFR § 91.119. 1 2 . Prior to any flight operations authorized by this petition of exemption, the PIC and VO must have successfully completed a qualification process , as outlined in the standard operating procedures manual. As this is a requirement stipulated by the operator, the test must be developed and implemented by a qualified person designated at the sole discretion of the CEO . A record of completion of this qualification process must be documented and made available to the A dministrator upon request.13 . Prior to operations conducted for the purpose of infrastructure inspection, a flight demonstration, administered by an operator

- approved/ qualified pilot must be successfully completed and documented. This documentation mu st be available for review upon request by the Administrator. Once the knowledge and airmanship test qualifications have been developed by the operator, and there are no established practical test standards that support a jurisdictional FAA FSDO evaluation and approval of company designated examiners, the petitioner will conduct these tests in accordance with the operator’s manual. 14 . The UA may not be operated directly over any person, except authorized and consenting personnel, below an altitude that is hazardous to persons or property on the surface in the event of a UAS failure or emergency. 15 . Regarding the distance from participating persons, the operator’s manual has safety mitigations for authorized and consenting personnel. At all times, tho se persons must be essential to the operations. 16 . Regarding distance from nonparticipating persons, the operator must ensure that no persons are allowed within 5 00 feet of the area , except those consenting to be involved and necessary for the infrastr ucture inspection operations. 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 inspecto r’s evaluation of the infrastructure inspection area to note terrain features, obstructions, buildings, safety barriers, etc. Such barriers may protect nonparticipating persons (observers, the public, news media, etc.) from debris in the event of an accide nt. 17 . If the UAS loses communications , or loses its GPS signal, the UAS must return to a pre

determined location within the security perimeter, and land or be recovered in accordance with the operator’s manual. 18 . The UAS must abort the flight in t he event of unpredicted obstacles or emergencies in accordance with the operator’s manual. 19 . Each UAS operation must be completed with 25% battery power remaining. 20 . The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver, or Authorization (COA) , prior to conducting any operations under this petition of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the o peration. 21 . All aircraft, operated in accordance with this exemption , must 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. Marking s must be as large as practicable. 22 . The operator must develop procedures to document and maintain a record of the UAS : maintenance, preventative maintenance, alterations, status of replacement/overhaul component parts, and the total time in service o f the UAS. These procedures must be added to the operator’s manual. 23 . Each UAS operated under this exemption , must comply with all manufacturer Safety Bulletins. 24 . The operator must develop UAS technician qualification c riteria. These criteria mu st be added to the operator’s manual. 25 . The preflight inspection section in the operator’s manual must be amended to include the following requirement s: t he preflight inspection must account for all discrepancies, i.e. inoperable components, items, or equipment, not covered in the relevant preflight inspection sections of the operator’s manual.26 . Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commissio n (FCC) or other appropriate government oversight agency requirements. 27 . At l east three days before scheduled infrastructure inspection with in the 5 mile radius of an airport, the operator of the UAS affected by this exemption must submit a written Pl an of Activities to the local FSDO with jurisdiction over the area of proposed infrastructure inspection. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must inc lude at least the following: a. Da tes and tim es for all flights b. Name and phone number of the opera tor for the UAS infrastructure inspection operations conducted under this petition of exemption c. Name and phone number of the person responsible for the on

- scene operation of the UAS d. Make, mod el, and serial or N

- number of UAS to be used e. Name and certificate number of UAS PICs involved in the infrastructure ins pection event f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the infr astructure inspection event; the list of those who gave permission must be made availabl e to the inspector upon request g. Signature of exemption

- holder or representative h. A description of the flight activity, including maps or diagrams of any : area, city, town, county, and/or state over which infrastructure inspection will be conducted , and the altitudes essential to accomplish the operation. 28 . The documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator, or any law enforcement official upon request. 29 . The UA must remain clear and yield the right of way to all other manned operatio ns and activities at all times. Including, but not limited to: ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc..

. 30 . UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be con ducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized. 31 . The UAS may not be operated by the PIC from any moving device or vehicle. Unless secured predesignated routes are used and the PIC is not operating the vehicle. 32 . The UAS may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 33 . The UAS may not operate in Class B, C, or D airspace without written approval from the FAA. The UAS may 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 NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administrator upon request.34 . Any incident, accide nt, or flight operation that transgresses the lateral or vertical boundaries of the operational area , as defined by the applicable COA, must be reported to the FAA’s UAS Integration Office (AFS

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

- 80 and authorization to resume operations i s provided. **Support for Petition for Exemption**

In accordance with the procedural require ments of 14 C.F.R. §11.81, Squadron Optics LLC provides the following information: Co ntact Information: Nathan Rea Owner/ Operator Squadron Optics LLC 3220 Honey Locust Dr. Loveland, CO 80538 (970)685

- 7602 squadronoptics@gmail.com **Regul atory Provisions from which Squadron Optics LLC**  **seeks an Exemption**

Squadron Optics LLC believes it may need an exemption fr om the following provisions to conduct the contemplated operations. In some instances, relief is needed because relief from another provision renders compliance with the regulation at hand infeasible. 333 Aircraft Exemption Status 14 C.F.R. §61.113(a) an d (b) 14 C.F.R. §91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. §91.203 (a) and (b) 14 C.F.R. §91.405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a)(1)&(2) 14 C.F.R. §91.417(a)&(b) Squadron Optics LLC believes an exemption is only needed f r om the above

- listed regulatory provisions. To the extent that the FAA believes that additi onal relief is required for Squadron Optics LLC to conduct the operations described here, we request an exemption from any such reg ulatory provisions as well. 3

3 F or example, 14 C.F.R. §91.417(a) imposes certain maintenance record keeping requirements “as applicable”. Since none of the underlying requirements (e.g., inspection intervals) can be met and will require an exemption, Squadron Optics LLC believes a separa te exemption should not be required for §91.417(a).**The Extent of Requested Relief and the Reasons Re lief is Needed** 

**Section 333 Aircraft Exemption Status:** Section 333 of the Modernization Act authorizes the FAA to exempt aircraft from the requiremen t for an airworthiness certificate based on a consideration of the size, weight, speed, operational capability of the particular UAS, as well as its proximity to airports and populated areas. An analysis of these criteria demonstrates that the sUAS operate d without an airworthiness certificate in the areas , and under the conditions contemplated by Squadron Optics LLC will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate , witho ut the conditions proposed in this request. The sUAS is less than 55 pounds fully loaded, carries neither a pilot nor passenger, and operates exclusively within a secured area. Unlike other civil aircraft s , operations under this exemption will be tight ly controlled and monitored by the operator and observer. Operations will be conducted in compliance with the FAA and with local public safety requirements to provide security for the area of operation , as is now done with conventional equipment, infrastru cture, bridge and out building evaluation. These safety enhancements provide an expanded degree of safety to the inspectors over conventional operations. Lastly, application of these same criteria demonstrates that there is no credible threat to national s ecurity posed by the sUAS, due to its : size, speed of operation, location of operation, lack of explosive materials , and inability to carry a substantial external load. Given the size and limited operating area associated with the aircraft to be utilize d by the Applicant, this meets the requirements of an equivalent level of safety under Part 11 and Section 333 of the Reform Act. The Federal Aviation Act (49 U.S.C.§44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft fro m the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and proximity to airports and populated areas of the particular sUAS. In all cases, an analysis of these criteria demonstrates that t he UAS operated without an airworthiness certificate, in the restricted environment, and under the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an airworthiness certificate w ithout the restrictions and conditions proposed. 14 C.F.R. §61.113(a) and (b) §61.113

**Private pilot privileges and limitations: Pilot in command.** (a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private p ilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.
**** * Squadron Optics LLC anticipates initially using a cadre of specially trained staff to conduct the sUAS operations. T hese indi viduals will not hold pilot licenses. The sUAS will not carry property for compensation or for hire since they will be used sole ly to assist in evaluation of the infrastructure, equipment, right

- of

- way, assets, bridges, tunnels and out

- buildings in furtherance of Squadron Optics client’s primary business . H owever, the employees’operation of the sUAS will not be incident al to their employment with Squadron Optics LLC, and they will be compensated for such work. Without an exemption, the pilot would be required to hold a commercial pilot certificate under §61.133. However, the risk associated with the contemplated operations is less than the risk posed by a traditional aircraft. The sUAS will fly at altitudes well below the permissible limits for other civil aircraft, eliminating the risk to other aircraft, and within a geographical envelop e under the sol e control of Squadron Optics c lients. Accordingly, t he risk would be limited to Squadron Optics personnel, who will be appropriately ou tfitted in safety gear, and Squadron Optics client’s property on the ground. Requiring a commercial pilot certificate would provide no appreciable safe ty benefit, and would needlessl y impose additional cost on Squadron Optics . Relief is needed from both paragraphs (a) and (b) because t he contemplated operations would not comply with §61.113(b)(1) and none of the other ex ceptions to paragraph (a) apply. 14 C.F.R. 91.119(c) §91.119 **Minimum safe altitudes: General.** Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: *** (c) Over other than congested areas. An altitude of 500 feet above the surface , except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.
***** Squadron Optics submits that the only relief it requires from §91.119 is from the minimum altitudes listed in paragraph (c). Relief is required from paragraph (c) for fixed wing operations because asset evaluation conducted at 500 feet or higher is insufficiently distinct to be meaningful. Since operations at this altitude also pose a heightened risk of collision with another aircraft, safety can only be assured through the grant of an exemption. The anticipated rotorcraft operations should be adequately addressed by paragraph (d) (1). Additionally, relief should not be needed from p aragraph (a) because an emergency landing of the aircraft, due to a power failure , will not create an undue hazard to persons or property on the surface. As noted in the explanation of why an exemption will n ot adversely affect safety, Squadron Optics clie nts have exclusive use of the land over which the sUAS will be operated, and public access is restricted. It also has exclusive use of significant portions of land adjacent to the infrastructure and structures that will be the objects of evaluation and ana lysis. Squadron Optics Clients tightly control access to land and have the ability to assure that no individuals unassociated with the planned operations are on the affected land. As such, the r isk of injury is minimal. Squadron Optics does not contemplate conducting operations over congested areas, so relief is not requested from paragraph (b).

14 C.F.R. 91.121 **14 C.F.R. §91.121 Altimeter Settings** This regulation requires each person operating an aircraft to maintain cruising altitude by reference to a n altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” ***** As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant tothe Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude

indicator before flight. Altitude information will be provided to the sUAS p ilot via a digitally encoded telemetric data feed, which downlinks from the aircraft to a ground

- based on

- screen display. This altitude information will be generated by equipment installed on board the aircraft, using GPS triangulation, or digitally encode d barometric altimeter, or radio altimeter, or any combination thereof. Prior to each flight, a zero altitude initiation point will be established and confirmed for accuracy by the pilot.

14 C.F.R. 91.151 **§91.151 Fuel requirements for flight in VFR con ditions.**  (a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed

– (1) During th e day, to fly after that for at least 30 minutes. (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assum ing normal cruising speed, to fly after that for at least 20 minutes. ***** Operating the sUAS in a pre

- defined area , with less than 30 minutes of reserve fuel , does not raise the type of risk contemplated by §91.151, i.e., that an aircraft could run out of fuel in the event it has to be flown to an alternate airport , or circle the planned airport in the event o f unanticipated conditions. Squadron Optics does not intend to use the sUAS for point

-to

- point flights , and will not operate the sUAS beyond visua l line of sight. Nor will the sUAS require an airport in order to land. Rather, Squadron Optics will operate the sUAS using pre

- planned flight paths (taking into account weather conditions) designed to allow the sUAS to fly to the point of intended landing . As such, there is no need for a time based excess fuel requirement. Rather it should be sufficient to require only as much additional excess flight capacity as necessary to safely land the sUAS. We believe that a 25% battery reserve is more than sufficie nt to meet this objective. 14 C.F.R. 91.405(a), 91.407(a) (1), 14 C.F.R. 91.409(a) (1)&(2) and 14 C.F.R. 91.417(a) & (b) **§91.405 Maintenance required.** Each owner or operator of an aircraft

– (a) Shall have that aircraft inspected as prescribed in subp art 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; ***** **§91.407 Operation after maintenance, preventive maintenance, rebui lding, or alteration.**  (a) No person may operate any aircraft that has undergone maintenance, rebuilding, or alteration unless

– (1) It has been approved for return to service by a person authori zed under §43.7 of this chapter. ***** **§91.409 Inspections.** (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had __ (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. ***** **§91.417 (a) & (b)** ***** Squadron Optics believes that an exemption from th ese three maintenance requirements is appropriate because the FAA has not developed maintenance standards that would allow an operator to meet the part 91 maintenance requirements. In particular, there are no individuals authorized by the FAA to approve a sUAS for return to service under §91.407(a) or to conduct the initial airworthiness and annual return to service inspecti ons required by §91.409(a). Squadron Optics will maintain the aircraft as instructed in the owner’s manual and ASTM F2909, where applic able, and will not operate the aircraft until it has reasonably determined that any needed repairs have been made. However, because of the technical impossibility of meeting the requirements of §§91.405(a), 407(a), 409(a) and 417(a) and (b), we believe an exemption from these provisions is appropriate.

Please do not hesitate to contact me at the phone number or via the e

- mail address provided above should you have any questions or concerns. Respectfully submitted,

N athan A. Rea Owner/Operator Squadron Optics LLC**Appendix A**

Summary for Federal Register Publication Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal Register should the FAA deter mine that publication is needed.

Petitioner: Squadron Optics LLC
Sections of 14 C.F.R. Affected: 333 Aircraft Exemption Status 14 C.F.R. §61.113(a) and (b) 14 C.F.R. §91.119(c) 14 C.F.R. §91.121 14 C.F.R. §91.151 14 C.F.R. §91.203 (a) and (b) 14 C.F.R. §91.405(a) 14 C.F.R. §91.407(a) 14 C.F.R. §91.409(a) (1) & (2) 14 C.F.R. §91.417(a)&(b) Description of Relief Sought: Petitioner seeks relief from the requirements of 333 Aircraft Exemption Status, 14 C.F.R., 61.113(a)&(b) , 91.7 (a), 91.11 9(c), 91.121, 91.151, 91.203 (a)&(b), 91.405(a), 91.407(a), 91.409(a) (1)&(2) , and 91.417(a)&(b) to c onduct sUAS operations over Squadron Optics LLC client owned or controlled land, solely during daylight hours, to assist in the safe evaluation and analysis of infrastructure and operations. In general, sUAS operations are intended to be conducted in areas remote from both congested areas and airports. The nature o f operations anticipated by Squadron Optics LLC requires that the sUAS be flown a t relatively lo w altitudes. Squadron Optics LLC expects that in most instances, the sUAS will be flown less than 100 feet from the highest structure along the path of the sUAS and in no instances will be flown higher than 400 feet above the ground. Accordingly, the risk of interference with other aircraft is minimal.**Appendix B**

3D Robotics X8+ See link to manual for X8 http://3drobotics.com/wp

- content/uploads/2014/03/RTF

-X8

- M anual

-V2.pdf