Raptor	Heli	UAV

281	N.	400	E.

Price,	Utah	84501

June	26,	2015

U.	S.	Department	of	Transportation

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Re:	 Raptor	Heli UAV	Request	for	Exemption	under	Section	333	of	the	FAA	

Reform	Act	and	Part	11	of	the	Federal	Aviation	Regulations

Dear	Sir	or	Madam:

Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	

Reform	Act)	and	14	C.F.R.	Part	11,	Raptor	Heli	UAV	hereby	applies	for	an	exemption	

from	the	listed	Federal	Aviation	Regulations	(“FARS”)	in	order	to	operate	small	

unmanned	aircraft	systems	for	commercial	applications	under	the	conditions	

outlined	herein	or	as	my	be	established	by	the	FAA	as	required	by	Section	333.

14	CFR	part	21,	subpart	H,	part	36

61.23(a)&(c),	61.101(e)-4	&	5,	61.113(a),	61.315 (a),	91.7(a),	91.119 (c),	91.121,	

91.151(a)-1,	91.405(a),	91.407(a)-1,	91.409(a)-1&2,91.417(a)&(b).

Raptor	Heli	UAV, a	Utah	based company	with	the	intent	of	operating	small	

unmanned	aerial	systems	for	imagery	and	data	collection.	The	sUAS	will	be	

equipped	to	conduct	aerial	photography	and	video,	multi-spectral	imaging, and	3D	

laser	scanning.		
Intended	Operations

Land	Surveys

Raptor	Heli UAV	intends	to	provide	a	safe	low-cost	aerial	time	specific	imagery	and	

elevation	assessment.	This	low	altitude	view	provides	clients	with	information	

about	soil	hydration,	irrigation,	pest,	and	fertilization	as	well	as	complications	and	

hazards.	This	type	of	data	collection	is	economical	and	substantially	increases	safety	

when	compared	to	the	use	of	a	traditional	manned	helicopter	or	plane. This	would	

also	aid	in	meeting	project	deadlines,	decrease	risk	of	exposure	to	field	operation	

personnel,	and	reduce	impact	to the	environment.

Inspections

Tower,	bridge,	power line,	pipe	line,	building,	home,	power	plant	and	other	similar	

inspections	would	be	preformed	with	the	increased	safety	and	lower	cost using	a	

sUAS,	Raptor	Heli	UAV will	offer	services	for	inspection	work.	All	inspection	work	

will	be	evaluated	for	safety	and	all	precautions	will	be	taken with	respect	to	persons,	

property,	and	national	air	space.	At	times	a	physical	fencing	may	be	used	in	areas	

that	have	a	need	for	additional	safety	due	to	property	close	to	the	flight	area.	

Inspections	preformed	by	a	sUAS	will	increase	the	level	of	safety	by	removing	risk	

from	personnel.	A	sUAS	will	increase	safety	by	keeping	persons	on	safe	terrain	and	

allowing	the	sUAS	to	provide	a	real-time	aerial	view	to	observers on	the	ground.

Inspections currently,	are being preformed	by	bucket	trucks,	helicopters,	or	

climbing	crews.	With	all	of	these	options	there	is	an	increases	risk	to	human	life	and	

an	environmental impact.	The	use	of	a	sUAS	would	substantially reduce risk	to	

persons, and have	a	much	lower	impact on	the	surrounding	environment	while	

reducing cost.

S&R,	Police,	Fire

Raptor	Heli	UAV	will	offer	services	to	aid	the	communities	nearby.		Safety	will	be	at	

the	forefront	of	any	such	work.	If	conditions,	in	the	air	or	on	the	ground,	are	found	

to	be	unsafe	Raptor	Heli	UAV	will	not	fly. Raptor	Heli	UAV	has	a	desire	to	help	the	

community	around	them	and	has	the	intension	of	assisting	local	government	

agencies	in	search	and	rescue	efforts	along	with	other	services	that	are	called	upon	

by	the	community.

Aerial	Imagery	and	Wildlife	Preservation

Raptor	Heli	UAV	will	preform	tasks	for	wildlife	conservation	and	study.	Also	

capturing	image	and	video	footage.		In	the	area	surrounding	Raptor	Heli	UAV	there	

are	many	types	of	wildlife	and	ecosystems.	Currently	they	are	being	surveyed	by	full	

size	helicopters.		These	helicopters	are	used	in	canyons	that	nest and	roost	eagles.	

The	canyons	are	also	home	to	prehistoric	art	work	and	structures.	Full	size	

helicopters	go	through	the canyons to	count	and	track	wildlife. The	use	of	a	sUAS	

would	limit	the	environmental	impact	to	such	areas	and	help	preserve	the	canyons.
All	of	the	proposed	operations	will	offer	an	increased	level	of	safety	due	to	the	

smaller	size	and	weight	compared	to the	use	of	a	full	sized	rotorcraft.	Being	

unmanned	will	reduce	risk	of	loss	of	life	to	pilot	and	crew.	The	sUAS	dose	not	carry	

gallons	of	fuel	that	a	full	sized	rotorcraft	does.	This	further	reduces	risk	to	human	

life	and	environment.	Use	of	a	sUAS	would	greatly	reduce	the	safety	risk	in	these	

proposed	operations.		Safety	to	persons,	property,	and	NAS	will	be	at	the	forefront	

of	all	Raptor	Heli	UAV	operations.	

sUAS	

Raptor	Heli	UAV	will	conduct	these	work	types	using	a	DJI	Inspire	1,	DJI	s900,	DJI	

1000, 3D	robotics	Solo,	and	a	DJI	Phantom	3	pro.	These	sUAVs	have	different	

capabilities	that	will	be	used	to	preform	the	different	types	of	work.	 All	these	sUAS’s	

have	been	named in	previous	exemptions and	have	shown	airworthiness.	

Raptor	Heli	UAV	submits	(see	attached)	the	sUAS	Aircraft	Manuals,	each	which	set	

forth	the	specifications,	inspection,	and	setup	of	the	sUAS	intended	for	use	in	the	

proposed	operations.

Safety

Raptor	Heli	UAV	places	safety	at	the	center	of	all	work	preformed.	

 Prior	to	each	flight	a	pre-flight	inspection	will	be	conducted. “Be	Safe	Before	

Takeoff” will	be	used	for	preflight	inspection. (see	attached)

 Alterations	and	repair will	be	preformed	by	the	manufacturer	or	designated	

technicians	capable	of	preforming	the	work	needed.

 All	controllers,	cameras,	and	any	other	equipment	used	will	be	FCC	

compliant.

 All	operations	will	be	preformed	by	one	of	the	sUASs	mentioned	within	

weighing	less	than	55	pounds.

 Speed	will	not	exceed	87knots	and manufacture	suggested	maximum	speed.

 Altitude	will	be	less	than	400	feet	above	ground	level. Usually	much	less.

 Speed	and	Altitude	limits	are	easily	set	before	takeoff.

 Visual	line	of	sight	will	be	kept	at	all	times.

 At	least	one	trained	visual	observer	will	be	used	during	any	flight. VO	will	be	

trained to	preform	all	duties	and	have	a	US	drivers	license	or	medical	

examination	to	ensure	physical	capability.

 Verbal	communication	will	be	kept	between	the	PIC	and	visual	observer(s).

 Operations	will	be	conducted	in	Day	VFR.

 All	permissions	and	needed	permits will	be	gathered	before	flight.	

 A	pre-flight	safety	assessment	of	the	area,	including	persons,	property,	and	

weather	will	be	preformed	before	each	initial	flight.

 The	UAS	will	yield	to	all	other	air	traffic.
The	PIC	will	meet	all	FAA	requirements.	This may	be	a	FAA	licensed	airman	with	a	

private	or	sports	pilot’s	certificate	or	have	passed	the	pilots	written	exam,	or	UAS	

certificate	(when	the	FAA	issues	the	criteria	and	procedures	for	a	UAS	license)	and	a	

second	class	medical	certificate	or	US	drivers	license.	

Proposed	sUASs	are	all	equipped	with	safety	features	and	abilities	that	ensure	safe	

flight	and	return.	These	are	available to	view in	each	UAS	safety	manual	(see	

attached).

Notification	of	flight	operations	to	the	FAA	will	be	consistent	with	the	Certificate	of	

Authorization	(COA)	requirements.	Raptor	Heli	will	notify	the	airspace	controlling	

authority	and	or	airport	management	at	non-towered	airports	prior	to	operating	

within 5	miles	of	an	airport. The	UAS	will	display	identification	markings	as	stated	

by	the	FAA.	

Analysis	of	the criteria	demonstrates	conditions	to	be	at	lest	safe	or	safer	than	a	

conventional	rotorcraft	due	to	the size,	weight,	speed,	operational	capabilities,	

contained	areas	of	operation,	and	within	visual	line	of	sight.	Raptor	Heli	UAV	is	

committed	to	a	“Safety	First”	atmosphere	and	will	conduct	operations	in	accordance	

with	all	Federal	Aviation	Regulations.	Furthermore,	granting	this	petition	is	in	the	

best	interest	of	the	public	as	it	will	save	money,	increase	efficiency,	decrease	

environmental	risks	and	impact.

Raptor	Heli	UAV	will	quickly	respond	to	any	questions	or	concerns and	look	forward	

to	working	with	you.	

Autumn	Jensen

Raptor	Heli	UAV

Simply	Great	Designs	LLC.

autumn@simplygreatdesigns.com