November 15, 2015

Docket Operations, M

-30 U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590

-0001

**Exemption Request Section 333 of the FAA Reform Act** To whomever it may concern, This petition is being submitted on our own behalf without legal counsel or consulting services. Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the Reform Act), and 14 C.F.R. Part 11, Advanced Aerial Imagery, a Northern California based company operating a Small U nmanned Aircraft System (sUAS) equipped to conduct aerial photography and survey for various industries, hereby applies for an exemption from the Federal Aviation Regulations listed below to allow operation of our sUAS commercially in airspace regulated by the Federal Aviation Administration (FAA) so long as such operations are conducted with and under the conditions outlined herein or as may be established by the FAA as required by Section 333. The requested exemption would permit Advanced Aerial Imagery t o pursue its commercial interests in providing services to consumers interested in aerial data capture and photography using a small advanced sUAS in the following areas: • Agricultural Surveying • Construction Surveying • Mining Surveying • Forestry S urveying • Commercial Surveying • Gas and Oil Inspections • Real Estate Photography • sUAS Operator Training• Product Demonstrations

• Research and Development

Advanced Aerial Imagery states that all sUAS flights that will occur over private or co ntrolled
access property will do so with the property owner's prior consent and knowledge and that only people who have consented or otherwise have agreed to be in the area where photography and videography will take place will be captured. Additionally, Advanced Aerial Imagery pilots will hold a minimum of a sport pilot license and if observers are not qualified pilots, they will be trained by Advanced Aerial Imagery pilots to understand the proper roles of an observer, communication procedures, proper vis ual scan techniques, operations at non

-towered airports, and appropriate sections of the Aeronautical Information Manual. Regulations from which the exemption is requested: 14 C.F.R. Part 21 14 C.F.R. 45.23 (b) 14 C.F.R. 61.113(a) and (b) 14 C.F.R. 91.7 (a) 14 C.F.R. 91.9 (b) (2) 14 C.F.R. 91.109 14 C.F.R. 91.119 14 C.F.R. 91.121 14 C.F.R. 91.151(a) 14 C.F.R. 91.203 (a) & (b) 14 C.F.R. 91.205 (b) 14 C.F.R. 91.215 14 C.F.R. (91.401

- 91.417)

The small Unmanned Aircraft System we a re petitioning for exemption to enable Advanced Aerial Imagery to operate is a Tarot T

- 810 multi

- rotor (hexacopter) which utilizes a Naza

- M V2 flight controller. The sUAS is equ ipped with a three

- axis gimbal and various cameras. This sUAS weighs less tha n 1 5 lbs., have a built

- in capability to limit the height it flies above the ground, to limit the radius of the distance it flies from the operator and to exclude it from Class B, C and D airspace including a no fly zone feature. Each system also has the fail

- safe function of the autopilot system, which means when the communication between the Main Controller and the transmitter is lost, the system will automatically trigger Return

-to

- Home and will land safely.The above specifications meet standards liste d below, some derived in accordance with the Model

Aircraft Operating Standards: • The petitioner will only operate the sUAS in line of sight of a pilot and/or observer and will operate at sites that are a sufficient distance from po pulated areas . Such operations will ensure that the sUAS will not create a hazard to users of the national airspace system or the public. • When flying sUAV within 5 miles of an airport, airport operators will be notified and the operator will give the right of way t o avoid flying in the proximity of full

-scale aircraft. • Maximum flight time for ea ch operational flight will be 30 minutes. • Flights will be terminated at 25% battery power reserve should that occur prior to the 30 minute limit. • The sUAS will be programmed so that it will not be operated at an altitude of more than 200 feet AGL, and not more than 200 feet above an elevated platform from which filming is planned. • Minimum crew for each operation will consist of the sUAS Pilot and the Visual Observe r. • The sUAS PIC's (Pilot in Command) will be an FAA licensed airman holding a minimum of a FAA Sport Pilot Certificate and second Class FAA Medical Certificate. • The sUAS operated by the petitioner weighs less than 55 pounds, including the payload (i. e. camera, lens, and gimbal). • The sUAS will operate at speeds of no more than 30 mph

. • Given the small size of the sUAS and the restricted sterile environment within which they will operate, our sUAS operations adhere to the Reform Act's safety requirements. Additionally, the fact that Advanced Aerial Imagery pilots will hold FAA Pilot certificates demonstrates that they have a high regard to safe operations with an understanding of FARs, pre

-flight inspections, maintenance and repair, operations with in airspace, as well as being t rained to high safety standards

. We respectfully request exemption under Section 333 to enable Advanced Aerial Imagery to operate safe, low

- risk commercial sUAV operations for the activities stated. Advanced Aerial Imagery will respect the space and privacy of citizens and property whilst keeping our skies safe at all times

. Sincerely, Nathan Edgar **Co**
**- Owner**  Advanced Aerial Imagery 236 Windrose Ct. Chico, CA 95973 530

- 518

-5604EXEMPTION REQUESTS AND EQUIVALENT LEVEL OFSAFETY

Advanced Aerial Imagery requests an exemption from the following regulations as well as any additional regulations that may technically apply to the operation of the sUAV System: **14 CFR Part 21, Airworthin ess Certificates**  This part establishes the procedures for the issuance of an airworthiness certificate. While the FAA continues to work to develop airworthiness standards for Unmanned Aerial Systems, we request an experimental certificate be issued for th e Tarot T

-810 sUAS with Naza

- M V2 controller under either or both of the following provisions: **21.191 Experimental certificates.** Experimental certificates are issued for the following purposes: **(a) Research and development.** Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft. **(b) Showing compliance with regulations.** Conducting flight tests and other operations to show compliance with the airworthiness reg ulations, including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations. Since th e experimental certificate can be used for commercial purposes such as market surveys,
sa les demonstrations, and crew training, we would expect that an experimental certificate would permit our commercial purpose as well. The aircraft will not carry person s or property, will not carry fuel, and will only fly under strict operational requirements. Combined with the UAS 's light weight, being constructed primarily of carbon fiber, and/or plastic, we propose that the UAS will be at least as safe, if not safer, than a conventionally certificated aircraft performing the same mission. If an experimental airworthiness certificate is not appropriate for this application, then we request an exemption of 14 CFR Part 21, Subpart H, and the requirement for an airworthine ss certificate in general, citing the equivalent level of safety outlined in the previous paragraph. **14 CFR 45.23 Display of marks; general and 45.29 Size of marks.** These regulations provide that each aircraft must display "N" and the aircraft's registra tion number in letters at least 3 inches high. Additionally, the aircraft must display the word "EXPERIMENTAL" in letters at least 2 inches high near the entrance to the cabin , cockpit, or pilot station. Thi s UAV does not have an entrance in which the word "EXPERIMENTAL" can be placed, and may not have a registration number assigned to it by the FAA. We propose to achieve an equivalent level of safety by including the word "EXPERIMENTAL" on one of the arms of the UAV (the biggest spot on the aircraft to pla ce such markings) , where the PIC, VO and others in the vicinity of the aircraft while it is preparing for launch will be able to see the designation. Additionally, we feel that the permanent placard discussed in the previous paragraph will provide the airc raft's registration information at the ground station. Finally, we will display at the ground station a high contrast flag or banner that contains the words "UnmannedAircraft Ground Station" in letters 3 inches high or greater. Since the aircraft will op erate within a visual

line of sight of the ground station, the banner should be visible to anyone that observes the aircraft and chooses to investigate its point of origin. **14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and61.13**  **3 Commercial pilot privileges and limitations.**  The regulation provides that no person that holds a Private Pilot certificate may act as pilot in Command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as pilot in
co mmand 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. Our proposed operations require th at the PIC must hold at least a Sport Pilot Certificate issued by the FAA and since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subparagraph (b) even though the intent of this application is to conduct a business. **14 CFR 91.7 Prohibits the Operation of an aircraft without an airworthiness**  **certificate.** As no such certificate will be applicable in the form contemplated by the FARs, this Regulation is inapplicable. **14 CFR 91.9 Civil aircraft flight manual, marking, and placard requirements.**  This regulation provides that no person may operate an aircraft unless a current, approved flight manual is in the aircraft. We assume that the intent of this requirement is to ensure that flight manual information is available to the aircrew while operating th e aircraft. We request an exemption to this requirement since the aircraft is not only too small to carry documentation; the documentation would not be available to the crew during flight operations. To obtain an equivalent level of safety and meet the int ent of 91.9, we propose that a current, approved sUAS Flight Manual must be available to the crew at the ground station anytime the aircraft is in, or preparing for, flight. **14 CFR 91.109 Flight Instruction; Simulated instrument flight and certain flight tests**  The regulation states that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully functioning dual controls." The sUAS ground

- based control station consists of a small hand

- held radio transmi tter and while it does not offer a second set of "controls", both the student and instructor can, and will, operate the single set of controls simultaneously. With both student and instructor having "hands

- on" the controls during flight, we feel that this technique meets the intent 91.109 and provides an equivalent level of safety. **14 CFR 91.119 Minimum safe altitudes: General.**  The regulation states that over sparsely populated areas the aircraft cannot be operated closer than 500 feet to any person, ves sel, vehicle, or structure. Since the typical mission of the sUAS would be photography or survey of persons, vessels, vehicles or structures it would be necessary to operate closer than 500 feet to the items listed. Operations will only be flown over prope rty or persons where permission has been obtained and careful pre

- planning has been performed. The aircraft will beoperated at a low altitude allowing, if a power unit fails, an emergency landing without undue hazard to

persons or property on the surface . Therefore we maintain that due to the small size of the UAS, the hazard to persons, vehicles and structures is minimal compared to manned aircraft, which should be considered in granting the exemption. **14 CFR 91.121 Altimeter settings.** The regulation requires that aircraft shall maintain cruising altitudes by reference to an altimeter setting available within 100 NM of the aircraft. The sUAS will always fly below 600 feet AGL and will not need to maintain cruising altitudes in order to prevent conflict with other aircraft. An Above Ground Level altimeter measurement above the takeoff point is transmitted via radio from the sUAS on

- board computer to the display screen held by the PIC, providing a constantly updated AGL readout. **14 CFR 91.151 Fuel require ments for flight in VFR conditions.**  The regulation provides that no person may begin a flight in an airplane under day

-VFR conditions unless there is enough fuel to fly to the first point of intended landing and to fly after that for at least 30 minutes. We feel the intention of this paragraph is to provide an energy reserve as a safety buffer for delays to landing. The sUAS are battery operated and the maximum duration of flight from a single battery charge is 12

- 20 minutes with a 20% reserve. Since the aircraft will never fly further than the visual line of sight (less than one mile) from the point of intended landing, a full battery charge at launch will ensure that we meet the reserve energy requirement of this paragraph. We request an exemption to the word "fuel" and ask for an equivalent interpretation with the word "energy". We also request exemption from the 30 min reserve and ask that our reserve will be to fly the mission to the point of intended landing and have at least a 20% battery reserve after that. **14 CFR 91.203(a) & (b) Civil aircraft: Certifications required.** The regulation provides that an airworthiness certificate, with the registration number assigned to the aircraft and a registration certificate must be aboard the aircraft. Addi tionally, subparagraph ( b) provides that the airworthiness certificate be "displayed at the cabin or cockpit entrance so that it is legible to passengers or crew." Our sUAS is too small to carry documentation, does not have an entrance, and is not capable of carrying passengers or crew. To obtain an equivalent level of safety and meet the intent of 91.203, we propose that documents deemed appropriate for thi s aircraft by the FAA will be located with the crew at the ground control station and available for i nspection upon request. In order to identify the aircraft, we propose that the information found on airworthiness and registration certificates be permanently affixed to the aircraft via placard containing the following information plus the word "EXPERIMEN TAL" to satisfy the requirement of 14 CFR 45.23. **14 CFR Subpart E (91.401**
**- 91.417)** 
**- Maintenance, Preventive Maintenance,**  **Alterations.** The regulation provides that the operator is primarily responsible for maintaining the aircraft in an airworthy conditi on, including compliance with part 39 and 43. Paragraphs 91.407 and 91.409 require that the aircraft be "approved for return to service by a person authorized under 43.7" after maintenance and inspection. It is our intention that the PIC perform maintenanc e and inspection of the aircraft and "be authorized to approve the aircraft for return to service." The PIC will ensure that theaircraft is in an airworthy condition prior to every flight and in addition, conduct detailed inspections

after every two hours of flight. Maintenance performed by the PIC is limited to repairing small cracks, replacing a propeller, checking electrical connections and updating software and firmware for the on

board computer. All other maintenance will be performed by the manufactu rer or their designated repair facility. The PIC will document work performed in accordance with 91.417. We feel that due to the size, construction, and simplicity of the aircraft, the PIC can ensure an equivalent level of safety.