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### Law Office ofDaryl Crouse 920 Orizaba Ave. Long Beach, CA 90804 (562) 342-4246 daryl@darylcrouse.com :l

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### Before the FEDERAL AVIATION ADMINISTRATION Washington, DC ....**~** ' '



### IN THEMATTER OF RADFLIGHT, INC. PETITION FOR EXEMPTION TO OPERATE SMALL UNMANNED AIRCRAFT SYSTEMS FAA Regulatory DocketNo.

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### I. SUMMARY RadFlight, Inc., aCalifornia company ("RadFlight"), located at 5684 Spinnaker Bay Dr., Long Beach, CA 90803 seeks authority to commercially operate aunmanned aircraft system fleet pursuant to Federal Aviation Regulations (14 C.F.R. § 

### 1.61) and Section 333 ofthe FAA Modernization and Reform Act of2012, 

### SpecialRules for Certain UnmannedAircraftSystems. RadFlight also seeks exemption from the requirements ofcertain provisions of14 C.F.R. Parts 21, 36, 45.23(b), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.133(b), 61.315(a), 91.7(a), 91.9 (b)(2), 91.103(b)(1), 91.109(a), 91.119(c), 91.121, 91.151, 91.203(a) and (b) 91.405(a), 91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b). Theproposed exemptions, ifgranted, would allow RadFlight to conduct commercial operations ofsmall unmanned aircraft systems ("UAS") weighing 55 pounds or less. 

### II. 

### BACKGROUND

RADFLIGHT, INC. PETITION FOR EXEMPTIONTO OPERATE SMALL UAS- 1RadFlight is a cutting edge engineering, cinematography and drone design company. 2 Consistent with Congressional intentin enacting Section 222, RadFlight seeks to utilize 3 remote flying and viewing technology to achieve new heights ofcreativity and production cost 4 5 savings. RadFlight seeks the requested exemptions and a Certificate ofAuthorization

6 permittingRadFlight to offer a suite ofservices, such as: 7 • Closed-set filming and aerial photography; • Aerial data collection; • Drone pilot and instructor training; 8 9 

### III. STATUTORYAUTHORITY 10 11 Section 333, 

### SpecialRules for Certain UnmannedAircraftSystems, provides a procedure

12 for seeking expedited FAA authorization for UAS operations in the NAS. SubpartA states the 13 FAA "shall determine ifcertain unmanned aircraft systems may operate safely in the national 14 airspace systembefore completion ofthe plan and rulemaking required by 332(b)(1) ofthis act 15 16 orthe guidance requiredby section 334 ofthis Act." In Section 332(b)(1), Congress made it

17 clear that section 333 provides a procedure for "expedited operational authorization." 18 Section 333(b) identifies factors that the FAA should consider in determining whether 19 commercial US operations should be approved when, "as a result oftheir size, weight, speed, 20 21 operational capability, proximity to airports and populated areas, and operation within the 22 visual line ofsight do not create a hazard to users ofthe [NAS] orthe public or pose a threatto 23 national security." 24 In addition, Section 44701(f) confers a general authority to grant exemptions from the 25 26 FAA's safety regulations and minimum standards when the administrator decides a requested exemption is in the public interest.

RADFLIGHT, INC. PETITION FOREXEMPTION TO OPERATE SMALL UAS- 22 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 IV.RADFLIGHTEXEMPTIONS REQUESTED RadFlight requests relieffrom: 14 C.F.R. Part 21 prescribes, in pertinent part, procedural requirements for issuing and changing design approvals; production approvals; airworthiness certificates; and airworthiness approvals. 14 C.F.R. Part 36 sets forth noise standards for aircraft type and airworthiness certification. 14 C.F.R. Part 45.23(b) sets forth the requirement, 

### ifapplicable, that the word "Restricted" be displayed on the unmanned aircraft near each entrance to the cabin, cockpit

orpilot station. 14 C.F.R. Part61.23(a) and (c) sets forth requirementsfor medical certificates. 14 C.F.R. Part 61.101(e)(4) and (5) prescribes recreational pilot privileges and limitations. 14 C.F.R. Part 61.113(a) and (b) prescribes private pilot privileges and limitations. 14 C.F.R. Part 61.133(b) prescribes commercial pilot privileges and limitations. 14 C.F.R. Part 91.7(a) prescribes, in pertinent part, that no person may operate a civil aircraft unless 

### itis in an airworthy condition. 14 C.F.R. Part 91.9 (b)(2) prohibits operation ofUS registered civil aircraft unless there is available in the aircraft a current approved Airplane orRotorcraft Flight Manual, approved manual material, markings, and records, or any combination thereof. 14 C.F.R. Part 91.103(b)(1) prescribes, in pertinentpart, that each pilot in command shell, before beginning a flight, become familiar with all available information concerning that

RADFLIGHT, INC. PETITIONFOREXEMPTION TO OPERATE SMALL UAS- 32 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 flight, include, "for any flight, runway lengths at airports ofintended use, and the following takeoffand landing distance:

... For civil aircraft forwards and approved Airplane orRotorcraft Flight Manual containingtakeoffand landing distance data is required, the takeoffand landing distance data contained therein." 14 C.F.R. Part 91.109(a) provides that "noperson may operate a civil aircraft (except in manned free balloon) that is being used for flight instructionunless the aircraft has fully functioning dual controls." 14C.F.R. Part91.119(c) prescribesthat, exceptwhennecessary fortakeofforlanding,

no person may operate an aircraftbelow the certain altitudes under certainconditions. 14 C.F.R. Part 91.121 requires, in pertinentpart, each person operating an aircraftto maintain cruising altitude byreference to an altimeter thatis set "to the elevation ofthe departure airport or an appropriate ultimate setting available before departure." 14 C.F.R. Part 91.151 prescribes that no person may begin a flight in an airplane under VFR conditions unless (consideringwind and forecast weather conditions) there is enough fuel to fly to the first point ofintendedlanding and, assuming normal cruising speed, (1) during the day, to fly after that for at least 30 minutes; or (2) at night, to fly after that for at least 45 minutes. 14 C.F.R. Part 91.203(a) and (b) prohibits, in subpart (a), any person operating a civil aircraft unless ithas within it (1) an appropriate concurrent airworthiness certificate; and (2)

an effective US registration certificate issued to its owner or, for operation within the United States, the second copy ofthe Aircraft Registration Application as provided for in §43.3 7(c).

RADFLIGHT, INC. PETITION FOREXEMPTION TO OPERATE SMALL UAS- 42 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Section 91.203 prescribes, in subpart (b), that no person may operate a civil aircraft unless and airworthiness certificate or a special flight authorization issued under §91.715 legible to passengers or crew is displayed at the capital cockpit. 14 C.F.R. Part 91.407(a)(1) prohibits, in pertinentpart, any person from operating an aircraft thathas undergone maintenance, inventive maintenance, rebuilding, or alteration unless ithas been approved for return to service by a person authorized under §43.7 ofthe

same chapter. 14 C.F.R. Part 91.409(a)(1) and (2) prescribes, in pertinentpart, that no person may operate aircraft unless, within the preceding 12 calendar months, ithas had an inspection for theissuance ofan airworthiness certificate in accordance with part 21 ofthis chapter. 14 C.F.R. Part91.417(a) and 

### (b) prescribes, inpertinentpart,thateachregistered

owner oroperator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records ofthe maintenance, preventive maintenance, and alteration and records ofthe 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance ofan aircraft. Therecords mustinclude- (i) A description (or reference to data acceptable to the Administrator) ofthe work performed; and (ii) The date ofcompletion ofthe work performed; and (iii) The signature, and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following information: (i) the total time in service ofthe airframe, each engine, each propeller, and each rotor. (ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The

RADFLIGHT, INC. PETITIONFOR EXEMPTION TO OPERATE SMALL UAS- 52 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 time since last overhaul ofall items installed on the aircraft which are required to be overhauled on a specified time basis, (iv) the current inspection status ofthe aircraft, including the time since the lastinspection required by the inspection program under which the aircraft and its appliances are maintained, and (v) The current status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method ofcompliance, the AD or safety directive number and revision date. Ifthe AD or safety directive involves recurring action, the time and date when the next action is required, and (vi) copies ofthe forms prescribedby §43.9(d) ofthis chapterfor eachmajor alterationtothe airframe and currently installed engines, rotors, propellers, and appliances. Therecords specified in paragraph (a)(l) ofthis section shall be retained until the work is repeated or supersededby other work orfor 1year after the work is performed. Therecords specified in paragraph (a)(2) ofthis section shall be retained and transferred with the aircraft at the time the aircraft is sold. A list ofdefects furnished to aregistered owner or operator under §43.11 ofthis chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. 

### V. RADFLIGHT'S OPERATIONS SATISFY SECTION 333 

### REQUIREMENTS

a. RadFlight's UAS Fleet RadFlight proposes to operate three small UAS under this exemption. 

### Phantom2

RADFLIGHT, INC. PETITIONFOR EXEMPTION TO OPERATE SMALL UAS- 62 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 RadFlight seeks an exemption to operate a DJI Phantom 2 for compensation or hire. The DJI Phantom 2is comprised ofa multi-rotor unmanned aircraft and two handheld ground control stations. The DJI Phantom 2 has a maximum gross weight ofapproximately 2.86 pounds, diagonal wheelbase ofl3.78 inches, and height ofapproximately 7.5 inches. The DI Phantom 2 is equipped with four rotors drivenby four lithium polymerbatterypowered electric motors. Design and operational characteristics are provided in DJIPhantom 2 Operating Manual (Page 35). 

### Phantom3 RadFlight seeks an exemption to operate a DJI Phantom 3 for compensation or hire. The DJI Phantom 3 is comprised ofa multi-rotor unmanned aircraft and two handheld ground control stations. TheDJIPhantom3has a maximum gross weight ofapproximately 2.821 pounds, diagonal wheelbase of13.78 inches, and height ofapproximately 7.5 inches. The DI Phantom 3is equipped with four rotors driven by four lithium polymer battery powered electric motors. Design and operational characteristics are provided in DJI Phantom 3 Operating Manual (Page 53). 

### DJIInspire RadFlight seeks an exemption to operate a DJI Inspire for compensation or hire. The DJI Inspire is comprised ofa multi-rotor unmanned aircraft and two handheld ground control stations. The DJI Inspire has a maximum gross weight ofapproximately 6.5 pounds, diagonal wheelbase of22.88 inches, and height ofapproximately 11.85 inches. The DJI- SlOOO is equipped with four rotors drivenby four lithium polymerbattery powered electric motors.

RADFLIGHT, INC. PETITIONFOREXEMPTION TO OPERATE SMALL UAS- 72 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Design and operational characteristics are provided in DJIInspire OperatingManual (Page 57). DJI-81000 RadFlight seeks an exemptionto operate a DJI-S1000 for compensation orhire. The DJI-S1000 is comprised ofa multi-rotor unmanned aircraft and two handheld ground control stations. The DJI-S1000 has a maximum gross weight ofapproximately 24.25 pounds, diagonal wheelbase of41.14 inches, and height ofapproximately 22 inches. The DJI- S1000 is equippedwith eightrotors drivenby eightlithiumpolymerbatterypoweredelectricmotors. Design and operational characteristics are provided inDJI S1000 Operating Manual (Page 22). b. PilotIn Command (PIC) and Operations All RadFlight Flight Crews, includingPIC and Visual Observers (VO), will be qualified

as directedby FAA and RadFlight Standard Operating Procedure (SOP). All flight crewmembers, including PIC and VO, will have an understanding of, and comply with, Title 14 Code ofFederal Regulations, and/or Agency directives and regulations, applicable to the airspace where the UAS will operate. Specifically all flight crew members will receive training on the rules and responsibilities described in 14 CFRPart 91 Sections 91.111, 91.113 and 91.115 regarding cloud clearance, flight visibility and the pilot controller glossary, including standardATC phraseology and communication. The PIC mustpossess at least a current private pilot certificate and third class medical certificate. ThePIC must also meet the flight review requirements specified in 14 CFR Section 61.56 in an aircraft in which thePIC is rated onhis/her pilot certificate.

RADFLIGHT, INC. PETITION FOREXEMPTIONTO OPERATE SMALL UAS- 82 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Prior to operations, the PIC must have accumulated and logged, in a manner consistent with 14 CFR Section 61.51(b), a minimum of25 hours oftotal time as a UAS pilot and at least tenhours logged as a UAS pilot with similar UAS type (fixed wing orrotary). Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this requirement. Training, proficiency, andexperiencebuildingflights arerequestedto be conductedunder this grant ofexception to accomplish the required flight cycles and flight time. Duringtraining, proficiency, and experience building flights, all persons not essential for flight operations will be considered non-participants and the PIC will operate the UAS with appropriate distance from non-participants in accordance with 14 CFR Section 91.119. The UAS shall remain clear and yield the right ofway to all other manned aviation operations and activities at all times. The UAS shall be operated at an altitude ofno more than 400 feet above ground level (AGL). All altitudes reported to ATC will be in feet. The multi-rotor UAS shall notbe flown at a ground speed exceeding 30 mph. Fixed wing and hybrid UAS shall be flown at a ground speed notto exceed the maximum design limitation air speed of57 mph as stated in the operating manuals. UAS Operations will be conductedunder visual meteorological conditions (VMC). TheUAS will notbeoperatedless than 500 feetbelow or less than 2000 feet horizontally from

a cloud or when visibility is less than 3 statute miles from the PIC. Ifthe UAS loses communications orloses its GPS signal, itmustreturn to a predetermined location within the planned operating area and land orbe recovered in accordance with RadFlight SOP.

RADFLIGHT, INC. PETITION FOREXEMPTION TO OPERATE SMALL UAS- 92 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 The UAS PIC must abort the flight in the event ofunpredicted obstacles or emergencies in accordance with operating documents. The UAS PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UAS with 25% batterypowerremaining.



### c. RadFlight's UAS Operating Parameters The UAS operatedin accordance with this proposed exemption shall be identified by serial numbers, registered in accordance with 14 CFR part 47, and have identification (NNumber) markings in accordance with 14 CFR part 45, Subpart C. Markings will be as large as practicable. The UAS documents required under 14 CFR 91.9 and 91.203 shall be available to the PIC atthe Ground Control Station ofthe UAS anytime the aircraft is operating. Those documents shall be available to the Administrator or any law enforcement official upon request. Any UAS incidents, accidents orflight operations that transgress the lateral orvertical boundaries ofthe operational area as defined by the applicable COA shall be reported to the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents shall be reported to the National Transportation SafetyBoard (NTSB) perinstructions contained on the NTSB Web site: www.ntsb.gov. Unless otherwise specified in this petition, the UAS PIC, and the UAS operations shall comply with all applicable parts of14 CFR including, butnotlimited to, parts 45, 47, 61 and 91.

RADFLIGHT, INC. PETITION FOREXEMPTION TO OPERATE SMALL UAS- 102 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 The UAS shall notbe operated over congested or densely populated areas. These areas include but are notlimited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). Each work site will also be evaluated based on local conditions. Operations ofUASmay be conductedatdistances less than 500 feet from participating persons, vessels, vehicles or structures that perform an essential function in connection with these special purpose operations. Operations closer than 500 feet from the PIC, VO, operator trainees and essential persons are permitted when operationally necessary; but never so close to present an undue hazard. This is consistent with Exemption No. 11138. Operations ofUAS may be conducted at distances less than 500 feet from unoccupied vessels, vehicles or structures owned by the land owner

### Icontroller when the land

owner

### Icontroller grants suchpermission, and the PIC makes a safety assessment ofthe risk from operations and determines that it does not present an undue hazard to persons or property. This is consistent with Exemption No. 11138. Flight operations will be conducted at least 500 feet from all nonparticipating persons unless barriers or structures are presentthat sufficiently protectnonparticipating persons from the UAS and/or debris in the event ofan accident. RadFlight shall ensure that nonparticipatingpersonsremainunder suchprotection. Ifa situation arises where nonparticipating persons leave such protection and are within 500 feet ofthe UAS, flight operations will cease immediately. This is consistentwith Exemption No. 11138.

RADFLIGHT, INC. PETITIONFOR EXEMPTION TO OPERATE SMALL UAS- 112 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 All operations ofUAS shall be conducted with the permission from the land

owner

### Icontroller or authorized representative. Permission from the land owner

### Icontroller or authorized representative will be obtained for each flight to be conducted. The UAS will not operate within 5 nautical miles ofan airport reference point as denoted on a currentFAA-published aeronautical chartunless a letter ofagreement with that airport's management is obtained, and the operation is conducted in accordance with a NOT AM as required by the operator's COA. Theletter ofagreement with the airport management will be made available to the Administrator upon request. This is consistentwith Exemption No 11159. The UAS mustbe operated within VLOS ofthe PIC and VO at all times. This requires the PIC to be able to use humanvision to see the UAS unaidedby any device otherthan corrective lenses, as specified on the PIC's FAAissued medical certificate. All UAS operations mustutilize aVO. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC mustbe able to communicate verbally at all times. The PIC and VO mustbe designatedbefore the flight and cannot transfer his orher designation for the duration ofthe flight. The PIC must

ensure that the VO can perform the functions prescribed in RadFlight's SOP. The UAS will notbe operatedby the PIC from any moving device or vehicle. Operations will notbe conducted during night as defined in 14 CFR 1.1. RadFlight will conductpreflight safety risk assessments to determine thatthe UAS is in a condition for safe flight (14 CFR Section 91.7(b)) and that the planned operation can be

RADFLIGHT, INC. PETITIONFOREXEMPTION TO OPERATE SMALL UAS- 122 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 completed safely. Specific procedures are addressed in RadFlight's SOP, and UAS Operation Manuals. RadFlight's operations do not require a notification to Flight Standards District Offices (FSDOs). RadFlight shall obtain an Air Traffic Organization (ATO) issuedCertificateofWaiver

or Authorization (COA) prior to conducting any operations under this requested grant of exemption. Additionally, RadFlight will request aNotice to Airmen (NOT AM) not more than 72 hours, butnotless than 48 hours prior to the operation. Prior to operations conducted for the purpose ofprecision agriculture (or similar operations), the PIC must have accumulated and logged in a manner consistent with 14 CFR Section 61.51(b), a minimum offive hours as a UAS PIC operatingthe make and model ofthe UAS to be utilized for operations under this requested exemption, and three take-offs and landings in the preceding 90 days. Training, proficiency, experience-building, and take-offand landing currency flights are requested to be conductedunder this grant ofexemption to accomplish the required flight time and 90 day currency. During training, proficiency, experience building, and take-offand landing currency flights all personnel not essential for flight operations are considered nonparticipants, and the PIC must operate the UAS with appropriate distancefrom nonparticipants inaccordance with 14 CFRSection 91.119. All operations must utilize aVO. The VO may be used to satisfy the Visual Line of Sight (VLOS) requirement as long as the PIC always maintain VLOS capability. The VO and PIC mustbe able to communicate verbally at all times. This condition and limitation is consistent with all FAA approved Exemptions.

RADFLIGHT, INC. PETITION FOR EXEMPTION TO OPERATE SMALL UAS- 132 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 

### VI. Rad.Flight's Requested Exemption Promotes the Public Interest Granting RadFlight's petition for exemption will further the public interestbecause RadFlight seeks to perform necessary and vital services for public and private organizations. Such services include research, education, agricultural, search and rescue. The RadFlight unmanned aircraft fleet are battery-powered UAS that serve as a safe, efficient, and economical alternative to the demand aircraft traditionally utilized in obtaining aerial imagery within these industries. An exemption allowing RadFlight's UAS fleet to operate would reduce the amountofmanned aircraft operatingintheNAS, reducenoise and air pollution. In addition, the safety oflife and propertyboth in the air and on the ground would be improved. By reducing the number ofmanned aircraft operating in the NAS airport congestion caused by arriving and departing aircraft will be reduced. The RadFlight UIS fleet does not require an airport to take offor land. A reduction ofmanned aircraft conducting aerial imagery flights would mean air traffic control handling less traffic during the ground, takeoff, departure, arrival and landing phases offlight operations. Aerial imagery missions using the RadFlight UAS fleet, instead ofmanned aircraft, benefits the public by drastically reducing air and noise pollution generated during manned aircraft operations. TheRadFlight UAS fleet, abattery powered electric motor, is the most viable environmentally conscious alternative to internal combustion aircraft. The maximum gross weight of5pounds perUAS has less physical mass for collateral damage to life and property whether on the ground or in the air.

RADFLIGHT, INC. PETITION FOR EXEMPTIONTO OPERATE SMALL UAS- 142 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 

### a. Exemption From TheRequirements OfSection 91.9(b) Would NotAdversely Affect Safety This exemption would maintain the level ofsafety established by Section 91.9(b) because RadFlight will keep the approved Airplane Flight Manual at the ground control stationwhere the pilot in command will have immediate access to the document. Previous exemptions granted by the FAAconcerning Section 91.9(b) establish that safety is not adversely affected when the approved Aircraft FlightManual is kept at the ground control station ofa UAS, where itcan be immediately accessed by the pilotin command. Section 91.9(b) "requires aircraft to carry the flight manual so the pilot would have ready

access to the aircraft limitations while in flight." Exemption No. 8607. However, the FAAhas also found thatUAS will always beoperatedwithoutany passengers or crew on board, andthat "requiringthese special-use aircraft [UAS] to carry superfluous paper documents may present

a safety hazard to the integrity ofthe [UAS]." Id. The FAA has previously granted exemptions in circumstances similar, in all material respects, to those presentedherein (e.g., Exemption Nos. 8607, 8737, 8738, 9299, 9430, 9554, 9564, 9565, 10167, 10602, 10673, 10835, 10869, 10968). 

### b. Exemption From TheRequirements OfSection 91.203(a) and (b) Would Not AdverselyAffect Safety This exemption would maintain the level ofsafety establishedby Sections 91.203(a) and (b) because RadFlight will keep the required documents at the ground control station where the pilot in command will have immediate access.

RADFLIGHT, INC. PETITIONFOREXEMPTIONTO OPERATE SMALL UAS- 152 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Previous exemptions grantedby the FAA concerning Sections 91.203(a) and (b) establish that safety is not adversely affected whenthe Airworthiness Certificate and U.S. registration certificate are kept at the ground control station ofthe UAS, where it can be immediately accessed by the pilot in command. Specifically, theFAAhas held thatthe intent ofSections 91.203(a) and (b) is better servedbyhaving the required documents in the control ofthe UAS operator (pilot in command), reasoning as follows: "Theoriginal intent ofthe subject regulation was to display the airworthiness and registration documents so they would be easily available to FAAinspectors and passengers for inspection and verification ofthe airworthiness and registration ofthe aircraft

... In this case, the aircraft will always be operated without any passengers or crew." Themissions for whichUASs areintendedwill preventtheneedfor aircraftnormally prescribed for civil aircraft. Further, itwill be operated on strictly confined missions from a known departure and arrival point, under the constant control ofa pilot-in-command. Requiring these special-use aircraft to carry superfluous paper documents may present a safety hazard to the integrity ofthe [UAS]. FAA operatinglimitations and special arrangements with Air Traffic Control (ATC) for surveillance of[UAS] flights adequately compensate for the requirements for carrying airworthiness and registration documents. Theintent ofthe regulation is better servedby having the required documents in the control ofthe aircraft operator and available for inspection under the special conditions prescribed in this exemption.

RADFLIGHT, INC. PETITION FOR EXEMPTION TO OPERATE SMALL UAS- 16The FAAhas previously granted exemptions in circumstances similar, in all material 2 respects, to those presented herein (e.g., Exemption Nos. 8607, 8737, 8738, 9299,9564, 9565, 3 4 10167, 10602, 10673, 10835, 10869, 10968).

5 

### VII. CONCLUSION 6 As setforth above, RadFlight seeks an exemption pursuantto 14 C.F.R. 

### § 11.61 and 7 Section 333 ofthe FAAModernization and Reform Act of2012, which will permit safe 8 operation ofthe RadFlight UAS fleet commercially, without an airworthiness certificate, for 9 10 the purposes described above. 

### By granting this Petition, the FAAAdministrator will be

11 fulfilling the Congressional mandate ofthe FAAModernization and Reform Act of2012, and 12 the public, by allowing RadFlight to safely, efficiently, and economically operate the UAS fleet 13 commercially within the NAS. 14 

### WHEREFORE, in accordance with the FederalAviation Regulations and the FAA 15 16 Modernization and Reform Act of2012, Section 333, RadFlight respectfully requests thatthe

17 Administrator grant this Petition for an exemption from the requirements of14 C.F.R. Parts 18 21, 36, 45.23(b), 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a) and (b), 61.133(b), 61.315(a), 19 91.7(a), 91.9 (b)(2), 91.103(b)(1), 91.109(a), 91.119(c), 91.121, 91.151, 91.203(a) and (b) 20 91.405(a), 91.407(a)(1), 91.409(a)(1) and (2), and 91.417(a) and (b). 21 22 Dated this 2July 2015. 23 24 25 26

RADFLIGHT, INC. PETITION FOREXEMPTION TO OPERATE SMALL UAS- 17