UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:
PLATFORMBROWN, INC. FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATION S SECTIONS 61.23(a) & (c), 61.101(e)(4) & (e)(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) & (a)(2), AND 91.417(a) & (b) CONCERNING COMME RCIAL OPERATION OF PRECISIONHAWK HAWKEYE AND THE CYPHY WORKS PARC UNMANNED AIRCRAFT SYSTEM S PURSUAN T

TO SECTION 333 OF THE F AA MODERNIZATION AND REFORM ACT OF 2012 ( PUBLIC LAW 112

- 95)

Submitted on August 21
, 201 5

G REGORY S

. W INTON , E SQ

. T HE A VIATION L AW F IRM 1997 Annapolis Exchange Parkway Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 Fax: (866) 568

- 9886 Attorney for Petitioner2 TABLE OF CONTENTS
Page

GLOSSARY OF ABBREVIATIONS

................................ ................................ ................. 3

SUMMARY

................................ ................................ ................................ ......................... 4

INTRODUCTION AND INTERESTS OF PETITIONER

................................ ................. 4

BACKGROUND

................................ ................................ ................................ ................. 5

BASIS FOR THE PETITION

................................ ................................ .............................. 5

NAME AND ADDRESS OF THE PETITIONER

................................ ........................ 6

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PLATFORMBROWN, INC. SEEKS EXEMPTION

................................ ................................ .......................... 6

THE EXTENT OF RELIEF PLATFORMBROWN, INC. SEEKS AND THE REASON PL ATFORMBROWN, INC. SEEKS THE RELIEF

................................ .... 7

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY AFFECT SAFETY

................................ ................................ .............. 10

THE REASONS WHY GRANTING PLATFORMBROWN, INC. 'S REQUEST WOULD BE IN THE PUBLIC INTEREST

................................ ............................... 23

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REG ISTER

.......... 26
ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO SUPPORT PLATFORMBROWN, INC.' S REQUEST

................................ ......... 2 7

CONCLUSION

................................ ................................ ................................ ................. 273 GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control
ATO Air Traffic Organization
C.F.R. Code of Federal Regulation s COA Certificate of Authorization
FAA Federal Aviation Administration
F AR Federal Aviation Regulation
FCC Federal Communications Commission
GCS Ground Control Station
GPS Global Positioning System
NAS National Airspace System
NOTAM Notice to Airmen
OEM Original Equipment Manufacturer
PIC Pilot I n Command
RTH Return To Home
Section 333 FAA Modernization and Reform Act of 2012 (FMRA) Section 333
UA Unmanned Aircraft
UAS Unmanned Aircraft System
VFR Visual Flight Rules
VLOS Visual Line of Sight
VMC Visual Meteorological Conditions
VO Visual Observer
VTOL Vertical Takeoff and Landing4 SUMMARY

P latformBrown
, Inc. (hereinafter “ P latformBrown ”) seeks exemption from the
requirements of 14 C.F.R

. §§ 61.23(a) & (c), 61.101(e)(4) & (e)(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) & (a)(2), and
91.417(a) & (b) , to operate the PrecisionHawk Hawkeye and the CyPhy Works P ersistent A erial

Reconnaissance and C ommunications Unmanned Aircraft System s (UAS) (hereinafter

“ Hawkeye ” and “PARC” , respectively
, or collectively the “subject UAS”) pursuant to Section

333 of the FAA Modernization and Reform Act of 2012 (FMRA)

. This exem ption will permit

P latformBrown to operate the two Unmanned Aircraft System s for the commercial purpose of

aerial data collection

.

INTRODUCTION AND INTERESTS OF THE PETITIONER

P latformBrown
, Inc. is o wned and operated under the Brown Aviation Lease umbrella

.
PlatformBrown was started out of the desire and necessity to create simplified solutions in the

field of aerial data collection . With the emergence of UAS technology and the pressure on the
FAA to mandate regulations on the operation of unmanned equipment, the market demanded a
solution that simplified the process around launching and managing a UAS project.

PlatformBrown ai ds its clients in determining the best equipment and course of a ction that will
suit their particular needs and operations.

The P latform Brown team is stacked with entrepreneurs with experience in aircraft
leasing, technology
, and service delivery. Brown Aviation Lease has a decade of experience
providing fleet manage ment and aircraft leasing solutions to top colleges, universities
, and flight
academies. With a fleet of over 100 training aircraft deployed across North America, Brown has
grown to become one of the largest owners of piston powered training aircraft. P l atformBrown5

will utilize the subject UAS to provide a safe, efficient, and effective means of conducting aerial
data collection operations for its clients.

BACKGROUND
Unmanned Aircraft System s : Hawkeye and PARC

PlatformBrown seeks an exemption to operate the Hawkeye and PARC UAS for
compensation or hire within the NAS

. The Hawkeye is comprised of a propeller driven, fixed
wing Unmanned Aircraft (UA) and a Ground Control Station (GCS). The Hawkeye has a
maximum gross weight, with payload, of approximatel y 5.5 pounds; measures approximately
39.3 inches long with a 59 inch wingspan; and has a maximum speed of 48.6 knots. T he PARC

is a tethered UAS system comprised of a vertical takeoff and landin g (VTOL) UA, a GCS , a TESS Base Station, and a TESS Spooler

. The PARC has a maximum gross weight, with
payload, of approximately 2 2 pounds; measures approximately 39 inches in diameter ; and can hover in wind speeds up to 35 knots. The PARC UAS is equipped with six ro tors mounted in a

hexa

- copter configuration
, each powered by an electric motor receiving power t hrough the

microfilament tether. The Hawkeye UAS is equipped with a single front

- mounted propeller
, driven by a Lithium Polymer b attery powered electric motor.

The Hawkeye UAS and PARC UAS that will be operated by PlatformBrown will be
registered in accordance with 49 U.S.C. 44103
, Registration of Aircraft
, as well as 14 C.F.R

. Part
47, Aircraft Registration
, and marked in accordance with 14 C.F.R. Part 45
, Identification and
Registration Marking

.
BASIS FOR THE PETITION

P latformBrown , by and through undersigned counsel, pursuant to the provisions of the
Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Moderniza tion and Reform Act6

of 2012, Section 333
, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the
Administrator to operate the subject UAS within the National Airspace System (NAS) , and for
an exemption from the requirements of 14 C.F.R. §§ 61.23(a) & (c), 61.101(e)(4) & (e)(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) & (a)(2), and 91.417(a) & (b). In consideration of their size, weight, speed, and
limited operating area, P latfo rmBrown ’s operation of the Hawkeye UAS and PARC UAS meets

the conditions of FMRA Sec tion 333. Additionally, The PrecisionHawk Hawkeye UAS was
most recently the subject of Grant of Exemption No. 12016 and the CyPhy Works PARC UAS is
pending approval under Grant of Exemption No. 12174.

A. Name A nd Address Of T he Petitioner

.
The name and address of the Petitioner is:

PlatformBrown
, Inc. 380 H anscom D r. B edford , MA, 01730
The point of contact for this P etition and specific contact information is as follows:
Gregory S. Winton, Esq. The Aviation Law Firm 1997 Annapolis Exchange Parkway
, Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 | Fax: (866) 568

- 9886 Ema il: Greg@aviationlawexperts.com

B. The Specific Sections Of 14 C.F.R. From Whic h PlatformBrown Seeks Exemption.

PlatformBrown seeks exemption f rom the following sections of Title 14 of the C ode of

F ederal R egulations:

 61.23(a) & (c) , entitled Medical certificates: Requirement and duration

 61.101(e)(4) & (e)(5) , en titled Recreational pilot privileges and limitations

 61.113(a)
, entitled Private pilot privileges and limitations: Pilot in command7  61.315(a) , entitled What are the privileges and limitations of my sport pilot certificate

 91.7(a) , entitled Civil aircraft airworthiness

 91.119(c) , entitled Minimum safe altitudes: (c) Over other than congested areas

 91.121 , entitled Altimeter settings

 91.151(a)(1) , entitled Fuel requirements for flight in VFR conditions

 91.405(a)
, entitled Maintenance required

 91.407(a)(1)
, e ntitled Operation after maintenance, preventative maintenance, rebuilding, or alteration

 91.409(a)(1) & (a)(2) , entitled Inspections

 91.417(a) & (b) , entitled Maintenance records

C

. The Extent Of Relief PlatformBrown Seeks And The Reaso n PlatformBrown Seeks The Relief

.
1. Extent of Relief PlatformBrown Seeks And The Reason PlatformBrown Seeks Relief From Section 61.23(a) & (c).

Relief from Section s 61.23(a) & (c) entitled Medical certificates: Requirement and

duration
, is requested to the extent necessary to allow an adequately certificated PIC holding an

FAA

- issued medical certificate or U.S. issued driver’s license , to conduct the proposed UAS
fligh t operations for compensation or hire

. This relief is requested since the limitations set forth in Section 61.23(a) state that the

holder of a recreational pilot, private pilot, commercial pilot, airline transport pilot certificate, or
fligh t instructor certificate must also hold the appropriate FAA

- issued medical certificate to
exercise the privileges of th e pilot certificate. Th e relief is further requested since the limitations
set forth in Section 61.23(c) state that the holder of a sport pilot certificate must also hold a U.S.
issued driver’s license when exercising the privileges of the certificate in a light sport aircraft.8

2

. Extent of Relief PlatformBrown Seeks And The Reason PlatformBrown Seeks Relief From S ection s 61.101(e)(4) & (e) (5), 61.113(a) , and 6 1.3 1 5(a)

.
Relie f from Section s 61.101(e)(4) & (e)(5), entitled Recreational p ilot privileges and

limitations ; Section 61.113(a)
, entitled Private pilot privileges and limitations: Pilot in

command ; and Section 61.315(a), entitled What are the privileges and limits of my sport pilot
certificate
, is requested to the extent necessary to allow a PIC holding a sport pilot, recreational
pilot
, or private pilot certificate , as well as an airman medical certificate or U.S. issued driver’s

license , and who has met certain flight

- hour and currency requirements
, to conduct the proposed

UAS flight operations for compensation or hire , subject to the conditions and limitations below

.
This relief is re quested since the limitations set for th in Section s 61.1 01(e)(4) & (e) (5)
state that no person who holds a recreational pilot certificate may act as pilot in command of an
aircraft for compensation or hire or in furtherance of a business. Relief is requested from
61.113(a) since the limitations set forth in th at section state that no person who holds a private
pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property
for compensation or hire ; nor may that person, for compensation or hire, act as pilot in command

of an aircraft

. Relief is requested from 61.315(a) since the limitations set forth in that section
only allow a person who holds a sport pilot certi ficate to act as pilot in command of a light

- sport

aircraft.

3

. Extent of Relief PlatformBrown Seeks And The Reason PlatformBrown Seeks Relief From Section 91. 7(a)

.
R elief from Section 91. 7( a)
, entitled Civil aircraft airworthiness
, is requested to the
extent required to allow PlatformBrown to determine that the subje ct UAS are in an airworthy

condition prior to every flight by ensuring that the subject UAS a re in compliance with t heir9

operating documents

. PlatformBrown seeks the requested relief because the subject UAS do not
require an air worthiness certificate in accordance with 14 C

. F

. R

. P art 21, Subpart H

.
4

. Extent of Relief PlatformBrown Seeks And The Reason PlatformBrown Seeks Relief From Section 91.119(c).
Relief from Section 91.119(c), entitled Minimum safe altitudes: (c) Over other than
congested areas , is required because a ll proposed operations of the subject UAS will take place

at an altitude at or below 400 feet AGL

. Th is relief is reques ted since the limitations set forth in
Section 91.119(c) state that no person may operate an aircraft below 500 feet above the surface

. Additionally, relief from Section 91.119(c) is requested to the extent necessary to allow
operations to be conducted c loser than 500 feet to persons, vessels, vehicles, or structures, under

certain conditions . This relief is requested since the limitations set forth in Section 91.119(c)
prohibit operating an aircraft closer than 500 feet to a person, vessel, vehicle, or structure.

5

. Extent O f Relief PlatformBrown Seeks And The Reason PlatformBrown Seeks Relief From Section 91. 121

. Relief from Section 91.121, entitled Altimeter settings , may b e required to allow flight
operations of the subject UAS
, because the subject UA S ’ altitude reporting equipment may be

set on the ground to zero feet AGL, rather than local barometric pressure or field altitude, before
each fligh t. Considering the limited altitude of the proposed operations, relief from 14 C

. F

. R

. §

91.121 is sought to the extent necessary to comply with the applicable conditions and limitations

stated below.

6

. Extent O f Relief Plat formBrown Seeks And The Reason PlatformBrown Seeks Relief From Section 91.151( a ) (1)

.
R elief from Section 91.151( a ) (1)
, entitled Fuel requirements for flight in VFR conditions
, is requested to the extent required to allow flights of t he subject UAS during daylight hours in

visual meteorological conditions (VMC)
, under visual flight rules ( VFR )

. PlatformBrown seeks10

the requested relief because without an exemption from Section 91.151( a ) (1) , the flight time

duration of the subject UAS will severely constrain the practicality of any aerial acquisition and

research flight op erations that PlatformBrown propose s to conduct pursuant to this Petition.

7

. Extent O f Relief PlatformBrown Seeks And The Reaso n PlatformBrown Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), A nd 91.417(a) & (b).

PlatformBrown requests relief from Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) &
(a)(2), and 91.417(a) & (b) to the extent necessary to allow the proposed operations in

accordance with the conditions and limitations set forth below. Since the aforementioned

Sections only apply to aircraft wit h an airworthiness certificate, PlatformBrown requests relief

from these Sections because the subject UAS do not require an airworthiness certificate.

D

. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided By The Rule From Which PlatformBrown Seeks Exemption.

1. Reasons Why The Subject UAS Meet The Conditions Of The FAA Modernizatio n and Reform Act of 2012 (FMRA) Section 333.
In consideration of the size, weight, speed, and operating limitations associated wi th the

unmanned aircraft and their operation, PlatformBrown ’ s operation of the subject UAS meets the

conditions of FMRA Section 333
, and will not require an airworthiness certificate in a ccordance
with 14 C.F.R. Part 21, Subpart H. I n seeking this exemption, PlatformBrown submits that
Hawkeye UAS and PARC UAS can operate safely in the NAS pursuant to FMRA Section 333,
as demonstrated by : ( a ) the characteristics of the Haw keye UAS and PARC UAS ; ( b ) the pilot

certification requirement; and ( c ) the specific operating limitations

. Additionally, the UAS and proposed operations requested in this petition are similar in all
material respects to relief p reviously requested in Gr ant of Exemption Nos. 11062, 11109,11

11112, 11213, 12016 and 12174
, and the reasons stated by the FAA for granting those
Exemptions also apply to the present situation

.

a . The S ubject UAS Are S afe For Use B ased U pon I ts S ize, W eight, S peed, A nd O per ati onal L imitations.
The operation limitations and specifications of the Hawkeye UAS are listed on pages 12
through 17 of the Hawkeye Aircraft Flight Manual, attached hereto as Exhibit A. Exhibit A
contains proprietary information and is to be held in a separate file. A complete description of
the operation and specifications of the Hawkeye UAS Ground Control Station is listed on pages
16, 23 through 25, and 49 through 50 of the Hawkeye Aircraft Flight Manual. The Hawkeye
UAS is compliant with all Fede ral Communications Commission (FCC) requirements.

The operation limitations of the PARC UAS are listed on page s 9 through 14 of the

PARC Aircraft Flight Manual , attached hereto as Exhibit B . Exhibit B contains proprietary

information and is to be held in a separate file. A complete description of the operation and
specifications of the PARC UAS Ground Control Station is listed on pages 12, 23, and 25
through 27 of the PARC Aircraft Flight Manual

. The PARC UAS does not transmit over any
frequency and the refore is compliant with all FCC requirements

.

i

. The Subject UAS ’ Autonomous Flight Features A nd Failsafes Enable Them To Remain Within A De fined O perational A rea.
The Hawkeye UAS and PARC UAS are enabled to enter autonomous flight under certain
contingency situations or at the command of the PIC

. The Hawkeye UAS autonomous features

include the following: a Return To Ho me (RTH) function and an Emergency Landing function

. The PARC UAS autonomous features include the following: a GPS Position and Altitude Hold

when initiated by the PIC ; a Return To Home function ; Flight Li mi ts ( i.e. , pre

- set limitations that

restrict t he distance and height o f the UA S flight operations) , and an Automatic Landing function12

initiated in contingency situations

. If the PARC UAS loses power through the tether
microfilament, an onboard battery po wers the UAS until it can perform a safe landing. A
complete description of the autonomous features and failsafes of the Hawkeye UAS is provided

at pages 28 through 40 of the Hawkeye Aircraft Flight Manual. A complete description of the

autonomous featur es and failsafes of the PARC UAS is provided at page s 24 through 27 and
pages 31 through 34 of the PARC Aircraft Flight Manual.

b

. Flight Operations Of The Subject UAS Are Limited To The Line Of Sight Of A Certificated Pilot I n Command With A Safety Observer.

PlatformBrown will only utilize certificated p ilot s who possess a current and valid FAA

issued ai rman m edical c ertificate or valid U.S. issued driver’s license to act as a pilot in

command (PIC) of the subject UAS. Additionally, a safety observer will assist all pilots during
flight operations.

c . Flight s Of The Subject UAS Will B e Conducted Pursuant To S pec ific Operating L imitations.
In seeking this exemption, Platfo rmBrown proposes to commercially operate the subject

UAS for the special purpose of conducting aerial acquisitions within the NAS
, pursuant to the
following specific operating limitations:
1. Operations authorized by this grant of exemption are limited to the PrecisionHawk Hawkeye and the CyPhy Works PARC Unmanned Aircraft System s when weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a new petition or a petitio n to amend this grant.

2. Operations for the purpose of closed

- set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspee d or calibrated airspeed to determine compliance with the 87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the aircraft manufacturer.13

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL

. 5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate or U.S. driver’s license

.
6 . All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the P IC and VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability

. The VO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or her designation for the duration of the flight. The PIC must also ensure that the VO can perform the duties required of the VO.

7

. This exemption and all documents neede d to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations an d made available to the Administrator upon request. If a discrepancy exists between the conditions and limitations in this exemption and the procedures outlined in the operating documents, the conditions and limitations herein take precedence and must be f ollowed. Otherwise, the operator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised docum ents to the Administrator or any law enforcement official upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that an y update or revisi on would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

- 80) may be contacted if questions arise regarding updates or revisions to the operating documents.

8

. Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional flight test prior to conducting further operations under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test flight must be conducted in such a manner so as to not pose an undue hazard to person s or property.

9

. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a condition for safe operation.

1 0

. Prior to each flight, the PIC must conduct a pre

- flight inspection and determine the UAS is in a condition f

or safe flight

. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment. If the14

inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from opera ting until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

1 1 . The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the air craft and aircraft components

.
1 2

. Each UAS operated under this exemption must comply with the manufacturer safety bulletins

.
1 3

. Under this grant of exemption, a PIC must hold either an airline transport, commercial, private, recreational, or sport pi lot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the fli ght review requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot certificate.

1 4

. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appro priate distances from persons, vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51 (b). Flights for the purposes of training the operator’s PICs and VOs (training, proficiency, and experience

- building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the U AS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted during dedicated training sessions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants in accordance with 14 CFR § 91.119.

1 5 . UAS operations may not be conducted during night, as defined in 14 C

. F

. R

. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). Flights under special visual flight rules (SVFR) are not authorized.

16 . The UA may not operate within 5 nautical miles of an airport reference point (ARP) as denoted on a current FAA Airport/Facility Directory (AFD) or for airports not denoted

w ith an ARP, the center of the airport symbol as denoted on the current FAA

- published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of

a greement with the airport management must be made available to the Administrator or any law enforcement official upon request

.
1 7 . The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.15

18 . If the UA loses communications or loses its GPS signal, the UA must return to a pre

determined location within the private or controlled

- access property.

19 . The PIC must abort the flight in the event of unpr edicted obstacles or emergencies

.
20 . The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power for the UA to conduct the intend ed operation and to operate after that for at least five mi nutes or within the reserve power recommended by the manufacturer if greater

.
21

. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA) . All operations shall be conducted in accordance with an ATO

- issued COA. The exemption holder ma y apply for a new or amended COA if it intends to conduct operations that cannot be conducted under the terms of the attached COA.

2 2 . All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance wi th 14 C

. F

. R

. part 47, and have identification (N

Number) markings in accordance with 14 C

. F

. R

. part 45, Subpart C. Markings must be as large as practicable.
23. Documents used by the operator to ensure the safe operation and flight of the UAS and any doc uments required under 14 CFR §§91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These documents must be made available to the Administrator or any law enforcement official upon reques t.
24. The UA must remain clear and give way to all manned aviation operations and activities at all times.
25. The UAS may not be operated by the PIC from any moving device or vehicle.

26

. All Flight operations must be conducted at least 500 feet from all nonparticipating persons , vessels, vehicles, and structures unless:
a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparti cipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating person s; and
,
b. The owner/controller of an y vessels, vehicles or structures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.16 The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under this exemption.

27 . All operations shall be conducted over private or controlled

- access property with permission from the pro perty owner/controller or authorized representative. Permission from the land owner/controller or authorized representative will be obtained for each flight to be conducted.

28 . Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions conta ined on the NTSB Web site: www.ntsb.gov.
If this exemption permits closed

- set motion picture and television filming and production, the following additional conditions and limitations apply.
29. The operator must have a motion picture and television ope rations manual (MPTOM) as documented in this grant of exemption.
30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) wi th jurisdiction over the area of proposed filming. The 3

- day notification may be waived with the concurrence of the FSDO. The plan of activities must include at least the following:
a. Dates and times for all flights; b. Name and phone number of the op erator for the UAS aerial filming conducted under this grant of exemption; c. Name and phone number of the person responsible for the on

- scene operation of the UAS; d. Make, model, and serial or N

- Number of UAS to be used; e. Name and certificate numb er of UAS PICs involved in the aerial filming; f. A statement that the operator has obtained permission from property owners and/or local officials to conduct the filming production event; the list of those who gave permission must be made available to the inspector upon request; g. Signature of exemption holder or representative; and h. A description of the flight activity, including maps or diagrams of any area, city, town, county , and/or state over which filming will be conducted and the altitudes essential to accomplish the operation.
31. Flight operation may be conducted closer than 500 feet from participating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.17

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.

2. Reasons Why An Exemption From The Requirements Of Sections 61.23 (a) & (c) Would Not Adversely Affect Safety.

PlatformBrown submits that an equivalent level of safety es tablished by Sections
61.23(a) & (c) will be maintained because no PIC will be allowed to operate the subject UAS

u nless that PIC holds either a valid FAA

- issued medical certificate or a valid U.S. issued driver’s
license. Additionally, no PIC will be allowed to operate the subject UAS unless that PIC has
demonstrated, by meeting minimum flight

- hour and currency requi rements, that the PIC is able
to safely operate the subject UAS in a manner consistent with the exemption, including evasive
and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles,

and structures.
Considering Platform Brown ’ s proposed area of operations, the relatively small size of the
subject UAS, and the operating limitations set forth in this Petition, as well as the parallel nature
of sport pilot, recreational pilot, and private pilot medical requirements, relating to the proposed
operations, PlatformBrown submits the additional requirements of at least a third

- class airman

medical certificate would not correlate to PlatformBrown ’ s proposed operations.

3

. Reasons Why An Exemption From The Requirements Of Section s 6 1.101(e)(4) & (e)(5), 61.113(a), and 61.315(a) Would Not Adversely Affect Safety.

PlatformBrown submits that an equivalent level of safety established by Section s
61.101(e)(4) & (e)(5), 61.113(a), and 61.315(a ) will be maintained because no PIC will be
allowed to operate t he subject UAS unless that PIC has demonstrated, by meeting minimum
flight

- hour and currency requirements, that the PIC is able to safely operate the subject UAS in a18

manner consistent with th e exemption, including evasive and emergency maneuvers and
maintaining appropriate distances from people, vessels, vehicles
, and structures.
Specifically, the PIC must have accumulated and logged, in a manner consistent with 14
C.F.R. § 61.51(b), 25 hours of total time as a UAS pilot ( with a minimum of 5 hours of those

hours as a UAS pilot operating the same make and model of UAS to be used for operations under
the exemption ). In addition to the hour requirements, the PIC must accomplish 3 take

- offs and
landings in the preceding 90 days (f or currency purposes).
Considering PlatformBrown ’ s proposed area of operations, and the operating limitations

set forth above; the parallel nature of sport pilot, recreational pilot, and private pilot aeronautical
knowledge requirements
, with re spect to the proposed oper ations, to those of commercial pilot
requirements ( See Exemption No s . 11062 and 11213 ); and the airmanship skills necessary to
safely operate the subjec t UAS, PlatformBrown submits that the additional mann ed airmanship
experience of a commercially certificated pilot would not correlate to the airmanship skills
necessary for PlatformBrown ’ s specific proposed flight operations.
As in Exemption Nos. 11062
, 11138, and 11153
, prior documented flight experience that
was obtained in compliance with applicable regulations will ensure an equivalent level of safety
during PlatformBrown ’ s proposed operations. The Administrator has held that prior documented
flight experience that was obta ined in compliance with applicable regulations would ensure safe
operations , stating as follows:
In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must ha ve accumulated and logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must a lso have accumulated and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than add itive; i.e.19

5 hours make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 take

- offs and landing s in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct PlatformBrown ’s proposed op erations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption to

ac complish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.
Exemption No. 11138 at page 15.
Accordingly, PlatformBrown will ensure safe operations by not allow ing any PIC to
operate the subject UAS unless that PIC has demonstrated
, by meeting minimum flight

- hour and

curre ncy requirements
, that the PIC is able to safely operate the subject UAS in a manner

consistent with the exemption, including evasive and emergency maneuvers and maintaining
appropriate distances from people, vessels, vehicles and structures.

4

. Reasons Why An Exemption Fr om The Requirements Of Section 91. 7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91. 7(a) will be maintained becau se prior to every flight, PlatformBrown will ensure that the subject UAS are in an airworthy

condition based up on the subject UAS’ compliance with their relevant operating documents , and

as stated in the conditions and limitations herein

.
5

. Reasons Why An Exemption From The Requirements Of Section 9 1.119(c) Would Not Adversely Affect Safety.
The equivalent level of safety established by Section 91.1 19(c) will be maintained

because in any operation to be conducted closer than 500 feet from any nonparticipating persons,
barriers or structures will be present to sufficiently protect any nonparticipating perso ns from

debris in the event of an accident during operation of the subject UAS , which weigh less than20

twenty

- two (22) pounds and will be operated below an altitude of 400 feet AGL. The
nonparticipating persons will be required to remain in the area of protection
, and i f any
nonparticip ating person leaves the area of protection and is within 500 feet of the subject UA S
, flight operations w ill cease immediately.
Additionally, any operation to be conducted closer than 500 feet from persons, vessels,
vehicles, and structures would first re quire the permission of the land owner/controller and a
safety assessment of the risk of operating closer to those objects by the PIC.

6

. Reasons Why An Exemption Fr om The Requirements Of Section 91. 121 Would Not Adversely Affect Safety.
The equivalent level of safety established by Section 91.121 will be maintained because

the altitude of the subject UAS will be reported to air traffic control (ATC) in feet above ground
level (AGL), and PlatformB rown will operate the subject UA S within visual line of sight, at or

below 4 00 feet AGL. Furthermore, the altitud e information of the Hawkeye UA will be
provided to the PIC via a barometric pressure senso r, GPS equipment, and a radio

communications teleme try data link, which downlinks from the UAS to the Ground Control
Station for active monitoring of altitude. The altitude information of the PARC UA will be
provided to the PIC via a barometric pressure sensor and GPS equipment linked through the

microfil ament tether to the ground control station for active monitoring of the flight path and

altitude

. Prior to each flight, a zero altitude initiation point is automatically establish ed by the
UAS at ground level.

7

. Reasons Why An Exemption F rom The Requirements Of Sec tion 91.151( a ) (1) Would Not Adversely Affect Safety.
A grant of this exemption would ensure an equiv a lent level of safety established by 14

C.F.R. Section 91.151( a ) (1) as a result of (1) the technical specifications of the subject UAS ; (2)21

the limitations on the proposed flight operations ; and (3) the location of the proposed flight
operations

. Accordingly, PlatformBrown will ensure that it will safely operate the subject UA S
during dayligh t hours in visual metrological conditions (VMC) under visual flight rules (VFR)
, with enough power for the subject UA S to fly after th e first point of intended landing for at least

f ive (5) minutes

. In addition to the level of safety established by the technical specifications of the UAS;

the limit ations on the proposed flight operations; and the location of the proposed operations, the
subject UAS provide audible and visual warnings to the PIC at the Ground Control Station when
the UA has low battery power remaining. Together
, these factors will en sure an equivalent level
of safety established by 14 C.F.R. Section 91.151( a ) (1)

.
P revious exemptions granted by the FAA concerning Section 91.151
, establish that safety
is not adversely affected when the technical characteristics and operating limitation s of the
subject UAS are considered. Relief has also been granted for manned aircraft to operate at less

than the minimums prescribed in Section 91.151 , including Exemption Nos. 2689, 5745, and

10650.

8

. Reasons Why An Exemption From The Requirements Of Sections 91.405(a),

91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.
In seeking this exemption, PlatformBrown submits that the equivalent level of safety with
regard to the regulatory maintenance and alteration requirements established by Sections
91.405(a), 91.407(a)(1), 91.409( a)(1) & (a)(2), and 91.417(a) & (b) will be met because a ll
maintenance, alterations, and preventive maintenance of the subject UAS performed by

Platfo rmBrown will be in accordance with the methods, techniques, and practices prescribed in

the operating documents

. Furthermore, only the Original Equipment Manufacturer (OEM) or22

qualified OEM maintainers will perform higher level inspections and maintenance per the
operating documents and OEM standards. PlatformBrown will document and maintain all

maintenance records for the subject UAS.

Since th e subject UAS will be inspected as prescribed by t he operating documents,

Platform Brown will maintain the equivalent level of safety established by Sections 91.405(a),
91.409(a)(1)
, and 91.409(a)(2)

. The following operating documents are attached hereto,
identified as the following Exhibits: (A ) The PrecisionHawk Hawkeye Aircraft Flight Manual;
(B) The CyPhy Works PARC Aircraft Flight Manual ; and (C) The P latformBrown s UAS Flight
Operations Manual

. The foregoing exhibits contain proprietary information and a re to be held in
a separate file p ursuant to 14 C.F.R. § 11.35(b).
Additionally , a n equivalent level o f safety established by Sections 91.407 (a)(1)
, 91.417(a)
, and 91.417(b) will be maintained because PlatformBrown will document and maintain

all of the maintenance records for the subject UAS

.
9

. T he FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Sec tion 333 of the FAA Modernization and Reform Act of 2012
(FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions
, PlatformBrown requests that the

FAA prescribe special conditions for the intended operation of the subject UAS , which contain
such safety standards that the Administrator finds necessary to establish a level of safety
equivalent to that established by 14 C.F.R. Part 21, Subpart H
, and 14 C.F.R

. §§ 61.23(a) & (c),
61.101(e)(4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a), 91.405(a),
91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) . Such special conditions will permit
safe operation of the subject UAS for the limited purpose of conducting aerial acquisitions within

the NAS for compensation or hire

. FMRA Sec tion 333 sets forth the requirem ents for23

considering whether a UAS will create a hazard to users of the NAS or the public
, or otherwise
pose a threat to national security; and further, provides the authority for such UAS to opera te
without airworthiness certification in accordance with any requirements that must be established
for the safe operation of the UAS in the NAS

.
Likewise , the Administrator may prescribe special conditions pursuant to 14 C.F.R.
§ 21.16
, for operation of the Hawkeye UAS and PARC UAS
, since the airworthiness regulations
of 14 C.F.R. Part 21 do not contain adequate o r appropriate safety standards
, due to the novel or
unusual design features of the aircraft . Section 21.16, entitle d Special Conditions , states the
following:
If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or unusual design f eature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16

. Therefore, in accordance with FMRA Sec tion 333 and 14 C.F.R. § 21.16 , the FAA may
prescribe s pecial conditions for PlatformBrown ’ s intended operation of the subject UAS , which
contain such safety standards that the Administrator finds necessary to establish a level of safety
equivalent to that established by 14 C.F.R. Part 21, Subpart H
, and 14 C.F.R Sections 61.23(a) &
(c), 61.101(e)(4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a), 91.405(a),
91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

.
E

. The Reasons Why Granting PlatformBrown ’s Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole

. Granting the present Petition will further the public interest by allowing PlatformBrown
to safely, efficie ntly , and economically provide UAS based services for its clients, in both the24

public and private sectors, seeking professional aerial data collection services in fields such as:
geospatial data collection, aerial photography, infrastructure inspection service s, and disaster
area damage and debris assessments

. Additionally, use of the subject UAS will decrease
congestion of the NAS, reduce pollution, and provide significant benefits to the economy.
Notably, the benefits of PlatformBrown ’s proposed operation of the subject UAS will be realized
without implicating any privacy issues.

2. The Public Will Benefit From Decreased Congestion Of The NAS.

The Hawkeye UAS is battery powered and the PARC UAS is powered from a ground

based electrical source. Both serve as a safe, efficient, and economical alternative to the manned
aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of manned
aircraft needed to perform aerial acqu isitions, an exemption allowing the use of the subject UAS
would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, and
increase the safety of life and property in the air and on the ground.
Furthermore, by reducing the num ber of manned aircraft operating in the NAS,
congestion around airports caused by arriving and departing aircraft will be reduced. The subject

UAS do not require an airport to takeoff or land. Likewise, a reduction of manned aircraft
conducting aerial survey missions would result in fewer aircraft that must be handled by air
traffic control during the ground, takeoff, departure, arrival, and landing phases of flight
operations.

3

. The Public Will Benefit From The Safety And Efficiency Of The Subject UAS.
Conducting aerial acquisitions with the subject UAS , instead of manned aircraft, will
greatly benefit the public by drastically reducing the levels of air and noise pollution generated
during traditional aerial survey flight operations. By using e lectric moto r s , the subject UA produc e25

no air pollution, and are the most viable environmentally conscious alternative to the cabin class,
six cylinder internal combustion twin engine aircraft that are typically utilized for aerial
acquisitions, and burn approximately 20

- 30 gallons per hour of leaded aviation fuel. The subject

UAS , while reducing the carbon footprint of aerial acquisitions , also reduce noise pollution, as
they are propelled by electric motors, rather than inter nal combustion engine s

. By using the subject UAS to perform aerial acquisitions, the substantial risk to life and
property in the air and on the ground, which is usually associated with traditional manned aircraft
flight operations, will be substantially reduced or completely eliminated. Aside from the lack of
flightcrew members located onboard the aircraft, the subject UAS , h ave less physical potential for
collateral damage to life and property on the ground, and in the air, compared to the manned

airc raft that typically conduct aerial acquisitions (weighing approximately 6,500 pounds with a
wingspan of approximately 40 feet, a length of 34 feet, and a fuel capacity of 180 gallons).
Additionally, using the subject UAS to perform aerial acquisitions wi ll increase the level
of safety and efficiency for PlatformBrown ’s employees, associated contractors, and public
employees by minimizing exposure to a number of hazards typically encountered in a field
environment, such as bridges, wetland areas, and steep terrain, as well as lowering the number of
incidents and associated costs, such as maintaining a certain level of insurance, that normally
coincide with operations in a hazardous field environment.

4

. Performing Aerial Acquisition Operations With The Subject UAS Will Benefit The Economy.
In addition to being safe and efficient, the subject UAS are also an economical alternative
to using manned aircraft to conduct aerial acquisitions . As such, operation of the subject UAS
will allow United States based companies, like PlatformBrown , to remain competitive and
contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and26

the Environmental Protection Agency (“EPA”) regulatory acti ons phasing out leaded aviation
fuels, U.S. owned and operated companies must adopt new and alternative technology in order to
remain competitive. Operati on of UAS such as th e one in this petition is one such technology
that not only allows companies gr eater operational flexibility compared to manned aircraft, but
provides such flexibility without the high operational cost of a traditional manned aircraft.
By operating UAS , companies such as PlatformBrown
, can remain competitive and
profitable , and therefore, provide greater job stability to employees and contractors, which will
ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S.
companies, through commercial use of the subject UAS , provides a stable wor kforce that
increases consumer spending; improves local, state, and federal tax revenues; and allows
companies to invest in research and development in order to remain competitive both in the

United States and abroad.

5

. There Are No Privacy Issues

.
Simil ar to the manned aerial acquisition flight operations that have been conducted for

d ecades, PlatformBrown ’ s proposed operation of the subject UAS will not implicate any privacy
issues. Specifically, the subject UAS will only be operated pursuant to the specific conditions

and limitations set forth herein , and in accordance with the Federal Aviation Regulations,
including the minimum altitude requirements of 14 C.F.R. § 91.119. Most significantly, the
subject UAS will not be o perated closer than 500 feet to any person, vessel, vehicle, or structure,

that is not directly involved in the operation unless specific conditions are met

.
F. A S ummary That C an Be P ublish ed In T he Federal Register, stating: The Rules From Which PlatformBrown Seeks Exemption:
PlatformBrown
, Inc. seeks exemption from the requirements of 14 C.F.R

. Sections 61.23(a) & (c), 61.101(e)(4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a), 91.4 05(a), 91.407 (a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)

.27

A Brief Description Of The Nature Of The Exemption PlatformBrown Seeks:
This exemption will permit PlatformBrown
, Inc. to commercially operate two Unmanned Aircraft System s (UAS) for the purpose of conducting aerial acquisitions within the National Airspace System (NAS)

.
G. Any Additional Information, Views, Or Arguments Available To Support PlatformBrown ’ s Request.

This Petition is made p ursuant to the FAA Modernization and Reform Act of 2012
(FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS
may operate safely in the N AS

. As such
, PlatformBrown ’ s request for exemption may be
granted pursuant to the authority of FMRA Sec tion 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the require ments for considering whether a UAS will create

a hazard to users of the NAS or the public
, or otherwise pose a threat to national security; and
further, provides the authority for such UAS to operate without airworthiness certification.

As discussed in detail above
, Platf ormBrown will operate the subject UAS safely in the

NAS
, without creating a hazard to users of the NAS
, or the public
, or otherwise pose a threat to
national security

. Additionally, The PrecisionHawk Hawkeye UAS was most recently the
subject of Grant of Exemption No. 12016 and the CyPhy PARC UAS is pending approval under
Grant of Exemption No. 12174.

CONCLUSION

As set forth herein
, PlatformBrown Aviation
, Inc. seeks an exemption pursuant to 14

C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA)
, which will permit safe operation of the Hawkeye UAS and PARC UAS commercially
, without

an airworthiness certificate
, for the limited purpose of conducting aerial acqu isitions within the
National Airspace System ( NAS )

. By granting this Petition, the FAA Administrator will be28

fulfill ing the Congressional mandate of the FAA Modernization and Reform Act of 2012, while

also adva ncing the interests of the public
, by allowing PlatformBrown to safely, efficiently, and
economically operate the subject UAS commercially with in the NAS

.
WHEREFORE , in accordance with the Federal Aviation Regulat ions and the FAA
Modernization and Reform Act of 2012, Section 333, PlatformBrown
, Inc. respectfully requests

that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R

Sections 61.23(a) & (c), 61.101(e)( 4) & (e)(5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121,
91.151(a), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b)
, and permit

PlatformBrown
, Inc. to operate the Hawkeye UAS and PARC UAS commercially for the
purpose of conducting aerial acquisitions within the NAS

.

Dated: August 21 , 2015 Respectfully submitted,

The Aviation Law Firm
/s/ Gregory S. Winton

____________________________ Gregory S. Winton, Esq. 1997 Annapolis Exchange Parkway Suite 300 Annapolis, Maryland 21401 Tel: (301) 294

- 8550 Fax: (866) 568

- 9886 Attorney for Petitioner