SHERIFF WALLY OLSON

P

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. BOX 279 DALE COUNTY · OZARK, ALABAMA 36361 October 4, 2015 U.S. Department ofTransportation Docket Operations, M-30 1200 NewJersey Avenue, SE Room W12-140, West Building Ground Floor Washington, DC 20590-0001 TELEPHONES: 334-774-2335 Fax: 334-774-2909 E-mail: wolson @dalecountysheriff

.com

Re: 

### Petition of Dale County Sheriff's Office for an Exemption Pursuantto Section 333 of the FAA Modernization andReformActof 2012 to operate an UnmannedAircraft System Dear Sir or Madam: Pursuant to Section 333 ofthe FAA Modernization and Reform Act of2012 (the Reform Act) and 14 C.F.R. Part 11, Dale County Sheriffs Office hereby applies for an exemption from the Federal Aviation Regulations identified below to allow for the commercial operation ofthe INDAGO Vertical Take-offand Landing (VTOL) System which is manufactured by Lockheed Martin.I. 

### REGULATIONS FORWHICHEXEMPTIONIS REQUESTED Dale County Sheriffs Office requests exemption from the following regulations: 

## • 14 C.F.R Part 21, Subpart H; 

## • 14 C.F.R Part 27; 

## • 14 C.F.R § 45.23(b); 

## • 14 C.F.R. §45.27(a); 

## • 14 C.F.R § 61.113; 

# • 14 C.F.R § 91.7(a); 

# • 14 C.F.R § 91.9(b)(2); 

## • 14 C.F.R § 91.9(c); 

## • 14 C.F.R § 91.103; 

## • 14 C.F.R § 91.109(a); 

## • 14 C.F.R § 91.119; 

## • 14 C.F.R § 91.121; 

## • 14 C.F.R § 91.151(a) & (b) 

## • 14 C.F.R § 91.203 (a) & (b); 

## • 14 C.F.R § 91.405(a); 

## • 14 C.F.R § 91.407(a)(l); 

## • 14 C.F.R § 91.409(a)(2); 

# • 14 C.F.R § 91.417 (a) & (b)

.

### II. STATUTORY AUTHORITY FORREQUESTED EXEMPTIONS This petition for exemption is submitted in accordance with Section 333 ofthe Reform Act. Congress has directed the FAA "to safely accelerate the integration ofcivil unmanned aircraft systems into the national airspace system." Pursuantto Section 333 oftheReform Act, the FAA Administrator is to permit operation ofanunmanned aircraft system where it does not create a hazardto users ofthe national airspace system (NAS) or the public orpose a threatto national securitybased onthe following considerations:

• The size, weight, speed and operational capability; • Operation inproximity to airports and populated areas; and • Operation within visual line ofsight ofthe operator. Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant exemptions from the agency's safety regulations and minimum standards when the Administrator decides a requested exemption is in the public interest. See 49 U.S.C. §§ 1

06(f), 44701-44716, et seq. A partyrequesting an exemption must explainthe reasons why the exemption: (1) would benefitthe public as a whole, and (2) would not adversely affect safety or how it wouldprovide a level ofsafety at least equal to the existing rules. 14 C.F.R. § 11.81. 

### III. DESCRIPTION OFDALE COUNTY SHERIFF'S OFFICE AND ITS SERVICES Dale County Sheriff's Office is a located in rural area ofSoutheastAlabama. Dale County is approximately 561.15 square miles. Our agency operations consist ofenforcement ofall public laws, protection ofthe county's court system, drug enforcement, search and rescue etc. We operate our own law enforcement aviation unit which consists ofthree helicopters and one airplane. Ourmissions cover a wide range ofoperations from surveillance, search and rescue, firefighting, swat, and patrol. Our aviationunit also supports a program calledProject Lifesaver which is a system that consists ofa small transmitterthat is wornbypersons that have cognitive disorders such as Autism, Down syndrome, and Alzheimer's. Primaryuses ofthe UAS will be Project Lifesaver search and rescue operation conducted by the Dale County Sheriff's Office. Other applications in the future will be tactical operations with SWAT suchas hostage barricaded subject with weapons etc. The contact information for the petitioner, Dale County Sheriff's Office, is as follows: Tim McDonald Dale County Sheriff's Office ChiefDeputy 113 West Reynolds St. P.O. Box 279 Ozark, AL 36360 tmcdonald@daleso.com www.daleso.com www.projectlifesaver.org 334-774-2335 or 334-379-9717

### IV. DESCRIPTION OF PROPOSED OPERATIONS Dale County Sheriffs Office is requesting exemptions from applicable Federal Aviation Regulations (FARs) pursuant to Section 333 ofthe Reform Actto perform aerial videography andphotography for search and rescue operations. Additionally Dale County Sheriffs Office will train other public safety agencies that will in tum operate underpublic use rules. A. The Aircraft Dale County Sheriffs Office will operate INDAGO manufactured by Lockheed Martin. The INDAGO 's autopilot has a high degree ofpre-programmed control and various built-in technical capabilities that strictly limit the potential for operation outside ofthe operating conditions set forth inthe exemption application. Hands-on experience with the INDAGO are a far more effective guarantee offlight safety than a commercial pilot certificate would be, until the FAA UAS Pilot Certificate requirements catch up to the SUAS technology. The INDAGO's autopilot has an all-digital software platform with advanced features previously restricted to full size unmanned aircraft. Automated features and advanced fly-safe controls enable safe, reliable operation, as well as advanced networking capabilities and system extensibility. • The system will be flown inmanual mode at all times. • Flight time and battery minutes are displayed at all times. The system will return home and land automatically ifuser-configurable limits are reached • Flight safetyis a priority, no matter the operating environment orproject. SUAS offer superior safety over manned aircraft byremoving the need for people to be onboard in potentially dangerous situations. With multiple built-in safety features, SUAS platforms are comparableto manned operations withrespect to safety • The INDAGO automatically detects potential issues- with configurable automated response behavior such as a return-home and automatic-landing routines • The INDAGO self-calibrates all ofits sensors and performs required failsafe pre-flight tests priorto takeoffto check for errors • The INDAGO has the ability to automatically returnto base in a loss oflink situation so the aircraft can'tfly horizontally orvertically beyondthe pre-planned flight area • The INDAGO has battery minutes and flight time displayed at all times. The system will return home and land automatically ifuser-configurable limits are reached • The INDAGO auto-detects a loss ofGPS, warns the pilot and initiates a landing based on user specifiedtimelines

--• Low battery on the INDAGG triggers a return to basefor. landing

-and

-batteryreplacemen • Ifthe INDAGO detects a loss-of-link withthe Ground Control Stationthe vehicle will returnto base and perform an automatic landing atthe takeoffpoint orother user defined return homepoint Considering the programmability and safety features ofthis UAV, it serves as the best optionto protectthe Public andNAS for the purposes ofthis petition.Dale County Sheriffs Office is using a UAV thathas the capability for taking offand landing at a single point, identical to a·helicopter. There are no runways, aided take offapparatuses, nor routes that need to be flown to areas being aerial video recorded orphotographed. Allowing a reduced and more confined areaofflight. The motors, rotors, propellers, body/frame, landing pads, etc. for the UAV utilized in this petition are not complicated. Engineering and design allows laymanmaintenance. Pre-flight inspections for cracks, damage or otherphysical conditions that could hamper safe flight will be conductedprior to any and all missions. Post flight inspections will also be conducted in orderto aid in identifying flight conditions thatmay cause stress to propellers, landing gear, etc. Thorough inspection ofthe UAV shall be conducted and flight response tested should a hard landing or crash occur insuring thatthe UAV can operate in a safe mannerbefore conducting any further missions. Like the Astraeus Petition Petitioner Dale County Sheriffs Office requests waiver or exemption for markings due to the small size ofthe fuselage for the INDAGO. Petitioner Dale County Sheriffs Office requests modification, waiver or exemption and clarification (within reason) concerning section 91.119 prohibition offlight in congested areas. Petitioner Dale County Sheriffs Office requests waiver for this condition to allow reasonable and responsible videography in congested areas ofsubdivisions and neighborhoods.
In compliance with Section 90.151 (a) the INDAGO is a battery operated UAVIUAS with battery level monitoring capability. Fully chargedbattery flight time is rated at 50 minutes respectively, with videos/photos taking much less time to record. Operator or PIC is warned when battery level is low. Petitioner Dale County Sheriffs Office requests waiver/exemption from Section 91.203 (a) since the INDAGO is a commercial and military grade UAVIUAS that should not require an airworthiness certificate. Posting ofspecial flight authorization would notbe possible since the INDAGO has no cabin and are not large enough to carry a certificate. However, a special flight authorization can be maintained bythe operator to make available uponrequest. B. Dale County Sheriff's Office Proposed Operations Demonstrate an Equivalent Level ofSafety 1. General Description ofProposed Flight Operations Dale County Sheriffs Officeproposes to operate withinthe limitations and performance specifications listed inthe user manuals which are summarizedbelow. These limitations provide for at least an equivalent, or higher, level ofsafety for operations underthe currentregulatory structure because the proposed operations represent a safety enhancementto the protocols. The proposed operations do not create any hazard to users ofthe national airspace system orpose a threatto national security. The aircraft is a battery operated quadcopter with a maximum flight time of50 minutes. The vehicle weighs approximately 5pounds. The vehicle will be operated

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### between 2 and 35 miles perhour, and it will operate at or below 200 feet AGL unless a separate COA is submitted. Manned aircraft are at risk offuel spillage and fire in the event ofan incident or accident. The INDAGO carries no fuel, and therefore the risk offire following an incident or accident due to fuel spillage is eliminated. Compared to manned aircraft, the unmanned aircraft being operated by the petitionerreduces the risk to participating persons in close proximity to the aircraft due to the limited size, weight, operating conditions, and design safety features ofINDAGO. The FAA has determined thatthe risk ofnot having an electronic means to monitor and communicate with other aircraft, such as transponders or sense and avoid technology, is mitigated by placing limits on altitude, requiring stand-offdistance from clouds, permitting daytime operations only, requiring thatthe aircraft be operated within visual line ofsight, and requiring INDAGO yield right ofwayto all other manned operations. Additionally, the operator will request a NOTAM priorto operations to alert other users ofthe NAS. See ExemptionNo. 11062, DocketNo. FAA 2014-0352, at p. 13. The petitioner's aircraft has the capability to operate safely after experiencing certain in- flight failures. The aircraft is also able to respond to a lost-link event with a precoordinated, predictable, automated flight maneuver. 

### 2. Reasons whythe exemption would not adversely affect safety or how the exemption would provide a level ofsafety atleast equalto the existing rule. Giventhe small size involved, the restricted environment within whichthey will operate, the procedures listed below, and pilot certificationrequirements, Dale County Sheriffs Office proposed operations using the INDAGO would "not create a hazard to users ofthe national airspace system or the public or pose a threat to national security." Reform Act Section 333(b) (1). 

### 1. The aircraft will be identified by serial number, registered with the FAA, and have identification (N-Number) markings as large as practicable. 2. Flights will be operated within visual line ofsight ofthe pilot in command (PIC). 3. Priorto each flight, a zero altitude initiationpoint will be established and confirmed for accuracy by PIC. 4. Maximum flight time for each operational flight will be approximately 50 minutes. 5. The aircraft will be safely landed withno less thanthe greater of(a) 20% battery life remaining or (b) three minutes offlight time remaining. 6. The aircraft will be operated during daylight and in VFRconditions. 7. Flights will be operated at a lateral distance ofat least 50 feet from any persons or property not associated withthe operation who have not givenpriorpermission. 8. Flights will be limited to a groundspeed of5-35 mph. 9. Minimum crew for each flight will consist ofa PIC and an Observer. 10. The PIC will possess at least a private pilot certificate and a valid state driver's license.11. Have completed and received certification in an INDAGO training program. 12. Have completed 10 hours (or 20 flights) oftraining on the SUAS and/or simulator before commencing commercial operations. 13. Prior to the flight, a Mission Plan will be created setting forth the limitations for the flight as well as contact information for the PIC. 14. The flight operations will yield the right ofway to other manned aircraft operations. 15. All persons who are not involved with flight operations will be required to stay 50 feet from the edge ofthe flight operationperimeter. 16. Dale County Sheriffs Office will provideNOT AM details to the FAA 24 hours prior to each flight. 17. All requiredpermissions and permits will be obtained from territory, state, county or cityjurisdictionsprior to flight. 18. Prior to commencing operations, Dale County Sheriffs Office will obtain a Certificate ofWaiver or Authorization (COA) from the FAA ifflying above 200 feet AGL. 19. Ifthe aircraft loses communications, it will have the capability to return to a predetermined location withinthe operational area and land. 20. Ifthe aircraft loses its GPS signal it will have the capability ofbeingflown manually to a predetermined location within the operational area and land. 21. The flight will be aborted incase ofunpredicted obstacles or emergencies. 22. Each flight will be recorded in an Operations Log Book. 24. Maintenance onthe aircraft will be recorded in a Maintenance Log Book. 

### V. SPECIFIC FAREXEMPTIONS REQUESTED Dale County Sheriffs Office seeks an exemption from several interrelatedprovisions of 14 C.F.R. Parts 21, 45, 61, and 91 for purposes ofconducting the requested operations using the INDAGO. Listed below are (1) the specific FAR sections for which exemption is sought, and (2) the operating procedures and safeguards that Dale County Sheriffs Office has established which will ensure a level ofsafety betterthan or equal to the rules from which exemption is sought. See 14 C.P.R. § 11.81 (e). 

### A. 14 C.F.R. Part21, SubpartH- Airworthiness Certificates and 14 C.F.R. § 

### 91.203(a)(1) The FAA has stated that no exemption is needed from this section ifa finding is made under the Reform Act that the UAS selected provides an equivalent level ofsafety when compared to aircraft normally used for the same application. These criteria are met, and therefore no exemption is needed. See Grant ofExemptionto Astraeus Aerial, DocketNo. FAA 2014- 0352 at 13-14,22. If, however, the FAA determines that there are some characteristics ofthe INDAGO that fail to meet the requirements ofthe Reform Act, an exemption is requested. 

### EquivalentLevelof Safety: The INDAGO is safe whentaking into account its size, weight, speed, and operational capability. The INDAGO weighs approximately 5 pounds will be flown at speeds of5-35 miles per hour, and invisual line ofsight ofthe operator. The INDAGO does not

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### -------carry pilots, passengers, explosive materials, orflammable liquid fuels. The INDAGO will be operated withinthe parameters ofthe User Manuals. Dale County Sheriffs Office will also provide the FAAwith advance notice ofall operations via a NOT AM and coordination withthe local Flight Standards District Office (FSDO). The proposed operations will be at least as safe as, or saferthan, conventional rotorcraft operating with an airworthiness certificate withoutthe restrictions and conditions proposedhere. 

### B. 14 C.F.R. Part27 Airworthiness Standards: Normal CategoryRotorcraft
14 C.F.R. Part 27 sets forth the procedural requirements for airworthiness certification ofnormal category rotorcraft. To the extentthe INDAGO would otherwise require certification under Part 27, Dale County Sheriffs Office seeks an exemptionfrom Part 27's airworthiness standards for the same reasons identified in the request for exemption from 14 C.F.R. Part 21, Subpart H. 

### C. 14 C.F.R. §§ 45.23(b), 45.27(a) and 91.9(c): AircraftMarking and Identification Requirements 14 C.F.R. §45.23(b), Markings ofthe Aircraft states: When marks include only the Roman capital letter "N" and the registrationnumber is displayed on limited, restricted or light-sport category aircraft or experimental orprovisionally certificated aircraft, the operator must also display 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.
14 C.F.R. 

### §45.27(a) states: 

### Rotorcraft. Each operator ofa rotorcraft must display onthat rotorcraft horizontally onboth surfaces ofthe cabin, fuselage, boom, ortail the marks required by§ 45.23.
14 C.F.R. 

### §91.9(c) states: Noperson may operate a U.S.-registered civil aircraftunless that aircraft is identified in accordance withpart 45 ofthis chapter. In a previous Grant ofExemption, the FAA determined that exemption from these requirements was warranted provided thatthe aircraft "have identification (N-Number) markings in accordance with 14 CFRpart45, Subpart C ifthe markings are "as large as practicable." See ExemptionNo. 11062, DocketNo. FAA 2014-0352, at p. 14. 

### EquivalentLevelof Safety: Dale County Sheriffs Office will mark all INDAGOs with theirNNumber in a prominent spot on the fuselage with markings that are as large as practicable.


### D. 14 C.F.R. § 61.113: Private Pilot Privileges and LimitationsDale County Sheriffs Office seeks exemption from 14 CPR§ 61.113, whichrestricts private pilots from flying aircraft for compensation orhire and would also require a second class medical certificate. The purpose ofPart 61 is to ensure that the skill and competency ofany PIC matches the airspace in whichthe PIC will be operating, as well as requiring certifications ifthe pilot is carrying passengers or cargo for hire. While the INDAGO will be operated as part ofa commercial operation, they carry neither passengers nor cargo. In the Grant ofExemption in FAA DocketNo. FAA-2014-0352, the FAA determined that the unique characteristics ofUAS operation outside ofcontrolled airspace did not warrant the additional cost and restrictions attendant with requiring the PIC to have a commercial pilot certificate and a class II medical certificate. The FAA has also determined that the required knowledge for a commercial pilot covers the same fundamental principles as a private pilot. The PIC will possess at least a privatepilot certificate, a third class medical certificate, and will have completed a Basic Operator Course for the INDAGO. The FAA stated in its grant ofan exceptionto Astraeus Aerial the "the FAA considers the overriding safety factor for the limited operations proposed by the petitionerto be the airmanship skills acquired through UAS-specific flight cycles, flight time, and specific make and model experience, culminating in verification through testing." See ExemptionNo. 11062, DocketNo. FAA 2014-0352, at p. 18. The proposed operations can achieve an equivalent level ofsafety by requiring the knowledge and experience in INDAGO operations described above. The restrictions Dale County Sheriffs Office has placed onits INDAGO operations meet or exceed the restrictions similarly imposed onAstraeus Aerial inFAA DocketNo. FAA-2014- 0352. Dale County Sheriffs Office will operate in restricted areas (the sites) away from persons and property not involved inthe operation. The aircraft will be flown based on VLOS at or below 400 feet AGL, so as to accommodate flight operations on specified sites. A NOT AM will be issued at least 24 hours before the flight is to occur, and the flight will be coordinated withthe applicable FSDO. 

### E. 14 C.F.R. § 91.7(a): Civil Aircraft Ainvorthiness Dale County Sheriffs Office seeks an exemption from 14 C.P.R. § 91.7(a), whichrequires that a civil aircraft be in airworthy conditionto be operated. The FAAhas stated that no exemption is required to the extentthat the requirements ofPart 21 are waived or found inapplicable. Accordingly, Dale County Sheriffs Office requests thatthe requirements for Section 91.7 be treated in accordance with FARPart 21 Subpart H. See Grant ofExemptionNo. 11062, p. 19. F. 14 C.F.R. § 91.9(b)(2): Civil Aircraft Flight Manual in the Aircraft; 14 C.F.R. §§ 91.203(a) and (b): Carrying Civil Aircraft Certification and Registration Pursuant to 14 C.P.R. § 91.9(b)(2):(b)No person may operate a U.S.-registered civil aircraft- (2)For which an Airplane or Rotorcraft FlightManual is required by§ 21.5 ofthis chapter, unless there is available inthe aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combinationthereof. Pursuant to 14 C.F.R. § 91.203(a) and (b): (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) ofthis section or a special flight authorization issued under§ 91.715 is displayed at the cabin orcockpit entrance so that it is legible to passengers or crew. Dale County Sheriffs Office does notrequest an exemption from this section but instead notifies the FAAthat, in accordance with FAA Office ofChiefCounsel's Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept atthe control station with the PIC during flight. The ChiefCounsel's Office has heldthat for all UAS operations, this alternate method constitutes full compliance with the regulations. See also Grant ofExemptionNo. 11062,pp. 19-20, and Grant ofExemptionNo. 8607. 

### G. 14 C.F.R. 

### § 91.103: PreflightAction Dale County Sheriffs Office seeks an exemption from 14 C.F.R. § 91.103, whichrequires a PIC to become familiar with specific information before eachflight, including information contained inthe FAA-approved Flight Manual onboardthe aircraft. The aircraft will not have a Flight Manual onboard. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoffdistances and aircraftperformance databefore initiation of flight. Underthese circumstances, the FAA has stated thatno exemptionis required. See Grant ofExemptionNo. 11062, p. 20. An exemption is requested to the extentthat anFAAapproved Flight Manual is required. 

### EquivalentLevelof Safety: An equivalent level ofsafety will be providedby following the User Manuals. The PIC will take all required preflight actions

- including performing all required checklists and reviewing weather, flight requirements, battery charge, landing and takeoff distance, aircraft performance data, and contingency landing areas - before initiation offlight. The UserManuals will be kept atthe ground station; with the operator at all times.

### H. 14 C.F.R. § 91.109(a): FlightInstruction Dale County Sheriff's Office seeks an exemption from 14 C.P.R.§ 91.109(a), whichprovides that "[n]o person may operate a civil aircraft (except a manned free balloon) that is being used for flight instructionunless that aircrafthas fully functioning dual controls." UASs and remotely piloted aircraft, by their design, do not have functional dual controls. Instead, flight control is accomplished throughthe use ofthe A2 Flight Control System/Ground Control Station (GCS) that communicates withthe aircraft viaradio communications. 

### EquivalentLevelof Safety: When flight instruction is performed, no pilots will be onthe aircraft and the GCS will be a safe distance from the aircraft and the public, causing no safety hazard. Given the size and speed ofINDAGO, an equivalent level ofsafe training can still be performed without dual controls because no pilot orpassengers are aboardthe aircraft, and all persons will be a safe distance away inthe event that the aircraft experiences any difficulties during flight instruction. These flights will comply with the provisions in the UserManuals. Accordingly, Dale County Sheriff's Office proposed method ofoperationprovides superior levels ofsafety. 

### I. 14 C.F.R. § 91.119(c): Minimum Safe Altitudes in Uncongested Areas Dale County Sheriff's Office requests an exemption from the minimum safe altitude requirements of 14 C.F.R. 

### § 91.119(c). Section 91.119(c) prescribes that an aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. The FAA has already determinedthat relieffrom Section 91.119(c) is warranted for UAS operations in uncongested areas with similar flight restrictions as those imposed by Dale County Sheriff's Office. See Grant ofExemptionNo. 11062, p. 20-21. 

### EquivalentLevelof Safety: Compared to flight operations withrotorcraft weighing far more thanthe maximum weights proposedherein, and giventhe lack offlammable fuel, any risk associated withthese operations is far less than those thatpresently exist with conventional aircraft. Anequivalent level ofsafety will be achieved given the size, weight, and speed ofthe INDAGO, as well as the locations where itis operated. In orderto avoid any riskto aircraft, flight operations will be restricted to 400 feet AGL orbelow. The INDAGO will be operated at sites, away from persons or structures not involved inthe operation. All persons who are not involved with Dale County Sheriff's Office operations will be requiredto be at least 50 feet from the flight operationperimeter. 

### J. 14 C.F.R. § 91.121: Altimeter Settings This petition seeks an exemption from 14 C.F.R. §91.121, which requires a person operating an aircraftto maintain cruising altitude or flight level by reference to an altimeterthat is set to the elevation ofthe departure airport. The INDAGO uses bothbarometric pressure sensors and GPS to determine altitude but do not have the ability to set in a current altimeter setting. An exemption is required to the extent thatthe INDAGO does not have a barometric altimeter setting. The altitude ofthe aircraft is monitored bythe PIC onthe ground control station and by the visual observer.

### EquivalentLevelof Safety: The FAA has stated that an equivalent level ofsafety canbe achieved ifthe aircraft will be operated at orbelow400 feet AGL and withinvisual line-of-sight in addition to GPS based altitude information relayed in real time to the operator. See Grant of ExemptionNo. 11062, p. 20-21. As the attached UserManuals indicate, the INDAGO will be operated at or below 400 feet AGL and comply with the limitations inthe Grant ofExemption No. 11062. 

### K. 14 C.F.R. 

### § 91.151(a): FuelRequirements for Flightin VFRConditions Dale County Sheriffs Office requests an exemption from 14 C.F.R. § 91.151(a)'s fuel requirements for flight in VFR conditions. Section 91.151 states: (a) No personmay begin a flight in an airplane under VFRconditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed

- (1) During the day, to fly afterthat for at least 30 minutes; or (2) At night, to fly afterthat for at least 45 minutes. Here, the technological limitations on INDAGO battery power means that no meaningful flight operations can be conducted while still maintaining a 30 minute reserve. The aircraft is battery powered with a maximum flight time ofbetween 50 minutes. Dale County Sheriffs Office proposes that the maximum flight time for each operational flight will be 50 minutes. The aircraft will be safely landed with no less than the greater of(a) 20% battery life remaining or (b) three minutes offlight time remaining. 

### EquivalentLevelof Safety: The FAAhas stated that an equivalent level ofsafety is provided if the UAS flight is conducted under daytime VFR flight conditions using VLOS, and terminated with at least 25% reserve battery power still available. See Grant ofExemptionNo. 11062, p. 21- 22. The User Manuals providing an equivalent level ofsafety by safely landing with no less than the greater of(a) 20% battery life remaining or (b) three minutes offlight time remaining and otherwise complying with the flight restrictions above. 

### L. 14 C.F.R. 

### §§ 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b): MaintenanceInspections Dale County Sheriffs Office seeks an exemption from the maintenance inspectionrequirements contained in 14 C.F.R. § 91.405(a), 91.407(a)(l), 91.409(a)(2); 91.417(a) and (b). These regulations specify maintenance and inspection standards inreference to 14 C.F.R. Part 43. See, e.g., 14 C.F.R. § 91.405(a) (stating that each owner or operator ofan aircraft "[s]hall have the aircraft inspected as prescribed in subpartE ofthis part and shall between required inspections

... have discrepancies repaired as prescribed inpart 43 ofthis chapter"). An exemption from these regulations is needed because Part43 and these sections only apply to aircraft with an airworthiness certificate, whichthe INDAGO will not have.

### EquivalentLevelof Safety: An equivalent level ofsafety will be achieved because maintenance and inspections will be performed in accordance withthe Manuals. This includes maintenance, overhaul, replacement, and inspection requirements for the aircraft and procedures to document and maintain maintenance records for the aircraft. This also includes preflightinspection procedures. See ExemptionNo. 11062, DocketNo. FAA 2014- 0352, at p. 14-15. As provided inthe Manuals, flights will notbe conducted unless a flight operations checklistis performed that includes all ofthe aircraft's components. The Manuals also set requirements for maintenance log books and record keeping as well as routine andpost-flight maintenance. The Manuals set requirements for both annual maintenance and preventative maintenance. 

### VI. PUBLIC INTEREST Granting Dale County Sheriffs Office petition for exemption furthers the public interest. National policy set by Congress favors early integration ofUAS into the NAS in controlled, safe working environments as proposed inthis petition. By granting this petition, the FAA will fulfill Congress's intent ofallowing UAS to operate safely in the NAS before completion ofthe rulemaking required under Section 333 ofthe Reform Act. Dale County Sheriffs Office will operate in a mannerthat will ensure the public's safety and will set the example for others to emulate. Itis well establishedthat UAS provide an additional tool for the public benefit, adding a greater degree offlexibility, which supplements the current capabilities offered by manned aircraft. 

### VII. PRIVACY All flights will be conducted in accordance with any federal, state or local laws regarding privacy. All flights will occur overprivate or controlled access property with the property owner'sprior consent and knowledge. Images orvideo taken ofindividuals will have consented to being filmed orotherwise they will be made anonymous. 

### VIII. NATIONAL SECURITY Giventhe small size oftheUAS involved and the restricted environment withinwhich they will operate, ourpetitionpresents no national security issue. Furthermore, the security screening conductedbythe Transportation Security Administration ofcertificated airmen satisfies the statutory requirement ofSection 333 for operations to not pose a threat to national St:l:urity. 

### IX. SUMMARYFORFEDERALREGISTER Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication inthe Federal Register, should itbe determined thatpublicationis needed: Dale County Sheriffs Office seeks an exemptionfrom the following rules in orderto provide aerial imaging, photography, videography and cinematography: 14 C.F.R Part 21, Subpart H; 14 C.F.RPart 27; 14 C.F.R §45.23(b); 14 C.F.R. §45.27(a); 14 C.F.R § 61.113; 14 C.F.R §91.7(a); 14 C.F.R § 91.9(b)(2); 14 C.F.R § 91.9(c); 14 C.F.R § 91.103; 14 C.F.R § 91.109(a); 14 C.F.R § 91.119; 14 C.F.R § 91.121; 14 C.F.R § 91.151(a) & (b) 14 C.F.R § 91.203 (a) & (b); 14 C.F.R § 91.405(a); 14 C.F.R § 91.407(a)(l); 14 C.F.R § 91.409(a)(2); 14 C.F.R § 91.417 (a) & (b). Operation ofthe INDAGO may substantiallyreduce the risk to life and property byperforming missions that are currently being performed by manned aircraft that are considered dangerous such as transmission tower inspections, firefighting or operating in extreme terrain or weather conditions. The INDAGO provides an efficient and quickly deployable solutionto provide Emergency Responders with increased situational awareness and minimizes risk to the emergency responsepersonnel and the public at large. The exemption will enhance safety byreducing riskto the operator, the general public and property owners from the hazards associated with operating UAS through deliberate planning, risk mitigation, and flight operations. 

### X. CONCLUSION Satisfaction ofthe criteriaprovided in Section 333 ofthe Reform Act- size, weight, speed, operating capabilities, proximity to airports and populated areas, operation within visual line of sight, and national security considerations

- provides more than adequatejustificationfor the grant ofthe requested exemptions to permit Dale County Sheriffs Office to operate the INDAGO. Granting the requested exemption will benefit the public interest as a whole in many ways, including (1) significantly improving safety and reducing risk by alleviating human exposure to danger; (2) improving the quality ofservices Dale County Sheriffs Office canprovide to its citizen's; and (3) decreasing the risks ofunmanned aircraft interfering with manned aircraft. Respectfully submitted, By: /s/ Tim McDonald ChiefDeputy Dale County Sheriffs Office