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	H eli	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	require d	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	inten t	of	operating	small unmanned	aerial	systems	for	imagery	and	data	collecti on.	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	da ta	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	pr oject	deadlines,	decrease	risk	of	exposur e	to	field	operation personnel,	and	red uce	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	i nspection	work.	All	inspection	work will	be	evaluated	for	safety	and	all	precautions will	be	taken with	respect	to	persons, p roperty,	and	national	air	space. At	times	a	physical	fencing	may	be	used	in	areas that	have	a	need	for	additional	safety	due	to	pro perty	close	to	the	flight	area. Inspections	preformed	by	a	sUAS	will	increase	the	level	of	safety	by	removing	risk from	person ne l. A	sUAS	will	increase	safety	by	keeping	persons	on	safe	terrain	and allowing	the	sUAS	to	provide	a	real - time aerial view	to ob servers on	the	ground. I nspections 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	th e	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	o f	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
. F ull	size helicopters	go	through	the canyon s to	count	and	track	wildlife. The	use	of	a	sUAS would	limit	the	environmental	impact	to	such	areas	and	he lp	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	fore front 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	wil l	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	wi ll	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	train ed	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	l icense. 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 convention al	rotorcraft	due	to	the size,	weight,	speed,	operational	capabilitie s, 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	al l	Federal	Aviation	Regulations.	Furthermore,	granting	this	petition	is	in	the bes t	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 concern s and	look	forward to	working	with	you. Autumn	Jensen Raptor	Heli	UAV Simply Great	Designs	LLC. autumn@simplygreatdesigns.com