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09/09/2015 **Nathaniel Sean Johnson Magna**  **Electronics Inc.**  **2050 Auburn Road Auburn Hills, MI 48326 USA**  **nate.johnson@magna.com 248** **- 696** **- 6492**  **09/09/2015 Attention:**  **U.S. Department of Transportation Docket Management System**  **1200 New Jersey Ave., SE Washington DC 20590**  Exemption Request Pursuant to Section 333 of the FAA Reform Act and Part 11 of the Federal Aviati on Regulations from: 14 CFR Part 21 subpart H; 14 CFR 45.23 (b); 14 CFR 61.113; 14 CFR 61.133; 14 ; 14 CFR 91.7 (a); 14 CFR 91.9 (b) (2); 14 CFR 91.103; 14 CFR 91.109; 14 CFR 91.119; 14 CFR 91.121; 14 CFR 91.151; 14 CFR 91.203 (a) and (b); 14 CFR 91.405 (a) ; 14 CFR 91.407 (a) (1) ; 14 CFR 91.409 (a) (2); 14 CFR 91.417 (a) and (b) , FAA 8900.227 Paragraph 16 (c) (4) PIC Medical and Paragraph 16 (e) (l) Observer Medical To whom it may concern: I am writing in regards to the FAA Modernization and the FAA Reform Act and the procedures contained in 14 C.F.R. 11, to request that Magna Electronics Inc. be exempted from the Federal Aviation Regulations ("FARs") listed below so that it may operate its small unmanned aircraft / lightweight unmanned aircraft systems ("U AS") commercially in airspace regulated by the Federal Aviation Administration so long as such operations are conducted within and under the conditions outlined herein by the FAA as required by Section 333. Magna Electronics Inc.’s exemption request would permit its operation of lightweight, unmanned (remotely controlled in line of sight) UASs in tightly controlled and limited airspace. As Magna is a Tier 1 automotive manufacturing company, the purpose of drone operation is to record media of Magna’s produ cts. This will include collecting test data at proving grounds and creating promotional material. Thus, Magna Electronics Inc. respectfully requests the grant of an exemption allowing it to operate lightweight, remote controlled UAS's. **The Specific Sections of Title 14 of the Code of Federal Regulations, Magna Electronics Inc. requests**  **exemptions are :**  **14 CFR Part 21 subpart H** The UAS to be operated carries neither pilot nor passenger and carries no explosive materials or flammable liquids. Given t he size, weight, speed, and limited operating area associated with the aircraft to be utilized, we request exception. In the restricted environment and under the conditions proposed operation will be at least as safe, or safer, than a conventional aircraft operating with an airworthiness certificate without said restrictions. **14 CFR 45.23 (b)**2

09/09/2015 Due to the size of this UAS it does not have a cockpit, cabin, or pilot station on which to m ark certain words or phrases. Due to the size of the craft we do not ex pect to write any information on it. **14 CFR 61.113 Private pilot privileges and limitations: Pilot in Command and 14 CFR**  **61.133 Commercial pilot privileges and limitations**  There are no means available for the pilot of a UAS to gain the experience in an equivalent category and class in order to apply for a commercial pilot's license
. Since the aircraft cannot carry passengers or property, we feel we meet the intent of 61.113 Subpa ragraph (b) even though the intent of this application is to conduct business. **14 CFR 91.7 (a)** As there will be no airworthiness certificate for the aircraft, should this exemption be granted, no FAA regulatory standard will exist for determining airwort hiness. Given the size of the aircraft for maintenance and use of safety, check list prior to each flight or an equivalent level of safety will be conducted. **14 CFR 91.9 (b) (2)** Given the size and configuration, the UAS has no ability to carry a flight manual on the aircraft. There is no room, capacity, or pilot on board to adequately carry flight manual. A n equivalent level of safety will be maintained by keeping the flight manual at ground control point where the pilot wil l have immediate access to it. **14 CFR 91.103** As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. The P ilot In Command ( PIC ) will take all actions under n ormal procedures including but not limited to; reviewing weather, flight battery req uirement, and landing and takeoff distances
. An equivalent level of safety will be provided by preflight protoco l to properly match the machine. **14 CFR 91.109** UAS and remotely piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraft via radio communications. The equivalent level of safety provided because neither a pilot nor passenger will be carried in the aircraft, and by the speed and size of the aircraft. **14 CFR 91.119** Since the UAS will be operating at a maximum of 400 feet Above Ground level ( AGL ) , we cannot comply with this requirement. The UAS will be operated 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 structure s is minimal compared to manned aircraft, which should be considered in granting the exemption.3

09/09/2015 **14 CFR 91.121** The UAS may not have a barometric altimeter, but instead does have a GPS altitude read out. An equivalent level of safety is achieve by the operator receiving live flight data monitoring and confirming current altitude along with altitude of launch site shown on GPS altitude indicator. **14 CFR 91.151** The UAS will not travel so far from the take off point that it cannot return before the battery reaches its reserve. The word “fuel” should be replaced with the word “energy” in this case. **14 CFR 91.203 (a) and (b)** Similar to, 14 CFR 91.9 (b) (2 ), g iven the size and configuration, the UAS has no ability to carry certificate and registration docume nts on the aircraft. There is no room, capacity, or pilot on board to adequately contain such documents. An equivalent level of safety wil l be achieved by keeping these documents at the ground control point where pilot has immediate access to them, to the extent they are applicable to the UAS
. **14 CFR 91.405 (a), 14 CFR 91.407 (a) (1), 14 CFR 91.409 (a) (2), 14 CFR 91.417 (a) and (b)**  Given these section s only apply to aircraft with an airworthiness certificate, theses section s do not apply
. As a safety precaution, operator will perform preflight inspections and ensure UAS is in working condition before initiating each flight. **FAA 8900.227 Paragraph 16**  **(c) (4) PIC Medical**  **and Paragraph 16 (e)**  **(l) Observer Medical** This policy provides that both the PIC a nd Visual Observer ( VO ) must have a valid FAA second class medical certificate in order to perform as a pilot or observer. Both the PIC and the VO are required to be in Visual Line Of S ight ( VLOS ) . Given the unlikely event that both the PIC and VO become m edically incapacitated while the aircraft is in flight, the UAS will return autonomously to the (a predetermined location) site of launching and land without crew intervention. Therefore, requiring the PIC and VO to meet the same medical requirements as a commercial pilot who is carrying passengers in a large aircraft is an unnecessary burden. We propose that the minimum medical requirements for the PIC and VO be visio n corrected to 20/20. The 20/20 vision requirement will ensure that the PIC and VO can see and avoid air traffic
. **AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY** The operation limitations proposed for an equivalent or higher level of safety because operations will further enhance the safety of the persons and/or property using conventional aircraft. These limitations and conditions to which the applicant agrees to adhere to when conducting commercial operations under the FAA include:

 The UAS will weigh less than 55 lbs.

 The UAS will have a maximum operating speed of no more than 70mph.4

09/09/2015  Flights will be operated within line of sight of the Pilot in Command (PIC) and Visual Observer (VO).

 Flights will be operated at an altitude below 400 feet Above Ground Level (AGL) and at least 100 feet above an y elevated platfo rm, unless the PIC or VO have access to that platform
.

 Minimum crew for each operation will consist of the UAS Pilot, the Visual Observer (VO) and may include but not limited to a Camera Operator.

 A briefing will be performed regarding the planned UAS operations prior to each day’s flight consisting of all the days’ activities.

 The flights will occur no closer than a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport.

 If operations will be within a 5 mile radius of the geographic center/Airport Reference Point (ARP) of a tower controlled or uncontrolled airport the respective airports will be contacted advising them of the estimated flight time, flight duration, elevation of flight and other pertinent information.

 The PIC and VO will have been trained and tested in operation of UAS and receive up
-to - date information for the particular UAS to be operated.

 The PIC and VO will be able to communicate by voice, radio, and/or text at all times.

 If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre
- determined location within a designated location and land autonomously.

 The pilot will have the capability to abort a flight in case of unpredicted obstacles, weather, or emergencies.

 All flight operations will be entered into a log. Commercial and Public Benefits: Granting Magna Electronics Inc. exemption request furthers the pu blic interest. First, Congress has already pronounced that it is in the public's interest to integrate commercially flown UASs into the national airspace system, hence the passing of the Reform Act. Second, Magna Electronics Inc. will conduct research into safe UAS operations every time it flies one of its UASs. Flight data, visual inspections, recorded observations and flight analyses will be compiled to further enhance current safety protocols. Allowing Magna Electronics Inc. to log more flight time directly relates to its research and its ability to further enhance current safety measures. Third, the public has an interest in reducing the danger and emission associated with current aerial cinematic capture methods, namely, full size helicopters. We may need to take the UAS out of the country to Canada because we have a portion o f our company located there. (possible reword)5

09/09/2015 Thank you very much for your time and consideration of this request. Please advise us if any additional information is required.