Aerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

1 

### 12 February 2016 Docket Operations M
- 30 , U.S. Department of Transportation (DOT) 1200 New Jersey Avenue, SE. Room W1 2
- 140 We st Building Ground Floor Wa shington, DC 20590
- 0001 Aerial Logistics N W LLC. DBA Vortex Aerial Imaging 4018 157 th 

### ST NW Gig Harbor, W A 98332 Attn : Chad Costa Subject: Request for Exemption Under FAA Modernization and Reform Act of 2012, Section 333, “ Special Rules for Certain Unmanned Aircraft Systems .” T o whom it may concern: Aerial Logistics N W LLC. DBA Vortex Aerial Imaging propose s to operate Unmanned Aircraft Systems (UAS) safely and routinely within the United States National Airspace System (NAS) in the normal conduct of its business. Because of the nature of our aircraft and the conduct of our bus iness, the company requests an exemption for its business operations under FAA Modernization and Reform Act of 2012, Section 333, Special Rules for Certain Unmanned Aircraft Systems

. Aerial Logistics N W is a LL C focused on providing aviation related service s . The company headquarters is 4018 157 th 

### St NW Gig Harbor , WA . 98332

. All contact and correspondence regarding this application shou ld be sent to the attention of Chad Costa at the above address, by telephone at ( 808) 651
- 6909 or by email at kauaichoppers @yahoo.com Sincerely,
Chad Costa OwnerAerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

2 

### Aerial Logistics N W LLC.Aerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

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### Request for Exemption under **FA A**  **Modernization and Reform A ct of 2012,**  **Section 333, “ Special Rules for Certain Unmanned Aircraft Systems.”**  Aerial Logistics N W LLC. DBA Vortex Aerial Imaging intends to safely conduct busin ess with Small Unmanned Aircraft (sUA)

– U nmanned A ircraft S ystems weighing less than 55 pounds. The company seeks the exemption because some of the rules applicable to manned aircraft and even larger UAS cannot be practically applied in our case. Per guidance provided in 14 CFR § 81 the company requests relief by exemption from the requirements of the following regulations :

 PART 21

– “Certification and airworthiness requirements for aircraft and parts,” Subpart 21.H

– “Certificates of airworthiness (except provisional certificates of airworthiness) and special flight permits”
 Part 61 Certification: Pilots, Fl ight Instructors, and Ground Instructors
 Part 91 General Operating and Flight Rules o 91.103(b)(2) Preflight action o 91.105 Flight crewmembers at stations o 91.109 Flight instruction o 91.119 Minimum safe altitudes o 91.121 Altimeter settings o 91.151 Fuel requirements for flights in VFR conditions o 91.405 Maintenance required o 91.407 Operation after maintenance o 91.409 Inspections o 91.417 Maintenance records **Summary**

**for the Federal Register (if posting is required)** Aerial Logistics N W LLC. proposes to operate Unmanned Aircraft Systems (UAS) safely and routinely within the United States National Airspace System (NAS) in the normal conduct of its business. Because of the nature of our aircraft and the conduct of our business, the company requests an e xemption for its business operations from certain rules contained in 14 CFR, Federal Aviation Regulations under Section 333 of Public Law 112
- 95 , “ 

### Special Rules for Certain Unmanned Aircraft Systems. ” **PA RT 21**  **– “Certification and airw**  **orthiness requiremen ts for aircraft and parts,”**  **Subpart 21.H –**  **“Certificates of airworthiness (except provisional certificates of airworthiness) and special flight permits** 
**. ”** Aerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

4 **Reason for the request**
- All the regulations under Part 21, Subpart H deal with airworthiness certificates for aircraft other than Small Unm anned Aircraft ( sUA). Currently sUA are not manufactured like m anned aircraft under 14 CFR regulations. C onsequently our sUA do not utilize FAA airworthiness standards or FAA Airworthiness Certificates. **Extent of relief**

– Aerial Logistics NW LLC request s relief from the rules of Subpart H because they are not applicable to Small Unm anned Aircraft (sUA). There are currently no FAA standards of airworthiness for sUA. Specifically, §21.175 taken from P art H entitled “ Certificates of airworthiness : classification , ” summarizes our request for relief from this part (Part 21, Subpart H)

. The regulation lists aircraft eligible for special and standard certificates of airworthiness. These are : prim ary, interm ediate or restricted categories, limited category, and am ateur
- built, light sport, experim ental and standard categories of aircraft. The standard certificate of airworthiness is issued for normal, utility, aerobatic, comm uter or transport category , manned free balloon or a special class of aircraft. sUA are not included in any of these airworthiness categories listed in Part 21, Subpart H. **Equal level of safety**

– An airworthiness certificate is an administrative requirem ent for manned aircraft constructed under the regulations of 14 CFR . Although it is required to be aboard a manned aircraft it does not necessarily prove an aircraft is both safe and airworthy

. Rather, p roper maintenance, safe and care ful operation a s well as docum entation that the FAA can track to check the aircraft and its operation is required for an aircraft to assure ai rworth iness with sUA. Aerial Logistics NW LLC intends to properly maintain their sUA within manufacturer’ s standards of maintenance and operational safe t y . Likewise the com

pany will carefully operate its aircraft within FAA standards in order to insure the safety of people and property we overfly

. Operating safely will also help us pre serve the company’ s assets . In lieu of an airworthiness certificate t

he FAA already provides a m eans to sufficiently m onitor sUA in general , and our sUA in particular

. The existing FAA requirem ent to register “Unmanned Aircraft (UA) operated for non
hobby or non
-recreational purposes” allows the FAA to track and m onitor sUA operations. Aerial Logistics NW will work in concert with the FAA Aircraft Registration Branch and the local FAA F

light Standards District Office (FSDO) in order to register our aircraft. In lieu of com plying with the rules of Part 21, subpart H , registration of our aircraft should provide t he FAA a m eans to monitor and ensure that our sUA operations are safe and lega l

. **Public benefit –**  Thousands of sUA without airworthiness certificates are presently operating safely within the National Airspace System (NAS). Increasing numbers of sUA in increasing numb e rs of makes and m odels are being m anufactured and sold each year. Issuing airworthiness certificates to the existing fleet alone would burden the public with the need to fund the m anpower and resources for doing so with no effect on the current levels of safety with which they currently operate in the NAS

. **S ummary** 

: Aerial Logistics NW LLC seeks relief from the rules associated with Part 21, Subpart H requiring airworthiness certificates for its Sm all Unmanned Aircraft (sUA)

. No regulation (including Part 21) currently exists which requires sUA to possess an a irworthiness certificate. A r equirem ent to issue airworthiness certificate s for sUA would unduly burden the FAA with its implem entation andAerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

5 general public with the costs of manpower and resources to issue a certificate for every sUA in commercial operation in the National Airspace System (NAS) . The com pany maintains that the FAA’ s requirem ent to register sUA operated for non
-hobby or non
-recreational purposes already allows the FAA to m onitor their safe use and proper maintenance as effectively as issuing an airworthiness certificate

. 

### Part 61 Certification: Pilots, Flight Instructors, and Ground Instructors **Reason for the request**

– The rules of 14 CFR Part 61 are not applicable to Sm all Unm anned Aircraft (sUA) because there is no cockpit and consequently no pilot in sUA. Neither is there a need for pilots, flight instructors or ground instructors in the sUA comm unity to com ply wit h the requirem ents of manned aircraft under 14 CFR Part 61. **Extent of relief**

– Aerial Logistics NW LLC requests relief from the rules of Part 61 as they apply to pilots, instructors and ground instructors since they apply to m anned aircraft. **Equal level of safety** 

– Although pilots and instructors as described in Part 61 are not necessary in sUA, our com

pany pilots, instructors and their training will parallel applicable parts of Part 61. Pilot training, instructor requirements and training syllabi a re addressed later in this docum ent. But com pany instructors and pilots will be trained on sUA to the sam e level of competency and focus on safe operations required of Part 61 pilots and instructors

. Consequently, the level of safe ty in sUA operation will mi

rror that already provided for through traditional Part 61 flight training. O ur pilots and instructors will use the same m ethodology and m uch of the sam e training m aterial used at flight schools for manned aircraft. Com pany t raining syllabi, training facilities, training aids, check flights and testing will also mi

rror Part 61 manned aircraft training requirem ents

. **Public benefit –**  The United States NAS is the safest in the world in part because of the standards set in training its pilots and instructors. The com pany intends to m odel the training of its instructors and pilots by using the same system that trains safe pilots in the US ma nned aircraft industry. Doing this will provide the general public with the benefit of the sam e level of safety in our sUA operation that the FAA currently maintains in m anned aircraft operations

. No further burden will fall on the FAA to require and mo nitor training that differs substantially with existing Part 61 training the agency currently m onitors. **Summary**

: Aerial Logistics NW LLC, which operates Small Unm anned Aircraft (sUA) seeks relief from the rules of 14 CFR Part 61 entitled “Certification: Pilots, flight instructors, and ground instructors.” Aerial Logistics NW LLC ma intains that because sUA are unm anned the rules of Part 61 do not apply to the com pany. Still, a s applicable to sUA, the com pany intends to use the sam e standards and m ethodologies for its pilots and instructors as currently used to train manned aircraft pilots and instructors under Part 61. Since the training for the com pany pilots and instructors will mi rror m anned aircraft training where applicable, the sam e level of safety and public good will be derived from its operation as is currently enjoyed within the United States National Airspace System (NAS).Aerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

6 

### Part 91 General Operating and Flight Rules **91.103 Preflight action**  **, (b)(2):** “ **For civil aircraft other than those specified in paragraph (b)(1)**  **of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight,**  **and wind and temperature. ”**  **Reason for the re quest** 

– The information required to com ply with the rule is not available for sUA in general

, and the sUA the com

pany will operate specifically. The manufacturers of sUA are not required to m eet the airworthiness standards specified in 14 CFR. Consequ ently, their performance is not tested or derived by 14 CFR standards nor mapped on charts or placards common to manned aircraft used in the US NAS. **Extent of relief**
- Aerial Logistics NW LLC request s relief from the rules of Part 91.103(b)(2) relating to aircraft performance planning for their operation of sUA

. **Equal level of safety**

– Operating procedures of the com pany include the same requirem ent as this rule e.g., for the pilot to insure the aircraft can be operated safely within the manufacturer’ s operating restrictions and recomm endations a s well as all applicable Federal Aviation Regulations . Further, com pany operating procedures require that the pilot conduct perform ance check s ( such as hover in and out of ground effect checks ) , ca reful flight planning and a detailed safety survey prior to conducting any flight. **Public benefit –**  Relieving the com pany of com

plying with rules not applicable to them allows the FAA to spend their assets and efforts e nsur ing that sUA operations use operating procedures and safety standards applicable to sUA. The public benefits by being able to utilize drones while still having the FAA oversight of their safe operation. **Summary**

: Aerial Logistics NW LLC seeks relief from the rules of Part 91.103(b)(2 ) relating to aircraft performance planning. The com pany notes that Small Unm anned Aircraft (sUA) are not manufactured under 14 CFR airworthiness standards. Consequently, performance charts and graphs typically used in manned aircraft are not available to plan a flight according to the guidance of the subject regulation. Com pany operating procedures require the pilots’ com pl iance with manufacturers’

restrictions, careful flight planning and that they conduct performance checks prior to conducting any flight

. 

### 91.105 Flight crewmembers at stations **- (a) During takeoff and landing, and while en route, each required flight crewmember shall**  **— (1) Be at the crewmember station unless the absence is necessary to perform duties in connection**  **with the operation of the aircraft or in connection with physiological needs; and (2) Keep the safety belt fastened while at the crewmember station.** Aerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

7 **(b) Each required flight crewmember of a U.S.**  **- registered civil aircraft shall, during takeoff and landing,**  **keep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does not apply if**  **— (1) The seat at the crewmember's stat**  **ion is not equipped with a shoulder harness; or (2) The crewmember would be unable to perform required duties with the shoulder harness**  **fastened. Reason for the request** 

– This regulation is only pertinent to ma nned aircraft as sUA have neither onboard cr

ew members, nor seats and seatbelts. **Extent of relief**

– Aerial Logistics NW LLC requests relief from the rules associated with crewm embers at their flight stations. **Equal level of safety**

– The safety concerns addressed by this regulation are only applicable to manned aircraft, not sUA. The level of safety assured by this regulation is unaffected by the com pany’ s relief from

its rules. **Public benefit –**  Without relief from this regulation the com pany and the public in general will not be able to use UAS operated for non
-hobby or non
-recreational purposes” Otherwise th ere is no benefit or loss to the public by relieving the com pany of compliance with the rules of this regulation. **Summary**

: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91.105 : “ Flight crewm embers at stations ” as Small Unm anned Aircraft operated by the com pany do not have crewm embers onboard, seats or seatbelts. 

### 91.109 **Flight instruction; S**  **imulated instrument flight and certain flight tests.**  **(a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. However, instrument flight instructi**  **on may be given in an airplane that is equipped with a single, functioning throw** **- over control wheel that**  **controls the elevator and ailerons, in place of fixed, dual controls, when —**  **(1) The instructor has determined that the flight can be conducted safely; and**  **(2) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.**  **(b) An airplane equipped with a single, functioning throw -**  **over control wheel that controls the elevator and ailerons, in pl**  **ace of fixed, dual controls may be used for flight instruction to conduct a flight review required by §61.56 of this chapter, or to obtain recent flight experience or an instrument proficiency check**  **required by §61.57 when —**  **(1) The airplane is equipped with operable rudder pedals at both pilot stations;**  **(2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the entire flight;** Aerial Logistics NW LLC

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8 **(3) The instructor is current and qualified to serve as pilot in command of the airpl ane, meets the**  **requirements of §61.195(b), and has logged at least 25 hours of pilot -**  **in -**  **command flight time in the make and model of airplane; and**  **(4) The pilot in command and the instructor have determined the flight can be conducted safely. (c) No person may operate a civil aircraft in simulated instrument flight unless**  **— (1) The other control seat is occupied by a safety pilot who possesses at least a private pilot**  **certificate with category and class ratings appropriate to the aircraft being flown.**  **(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and**  **(3) Except in the case of lighter -**  **than -**  **air aircraft, that aircra ft is equipped with fully functioning**  **dual controls. However, simulated instrument flight may be conducted in a single -**  **engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the**  **elevator and ailer ons, when**  **— (i) The safety pilot has determined that the flight can be conducted safely; and**  **(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.**  **(d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot**  **certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked,**  **is fully qualified to act as pilot in command of the aircraft.**  **Reason for the request**

– This regulation is only pertinent for manned aircraft with standard flight controls operating with a pilot and a flight instructor, flying in either visual or instrum ent conditions. **Extent of relief**

– Because our sUA do not carry pilots or fly in instrum ent conditions, t he com pany requests relief from

the rules associated with dual pilot, in
- cockpit flight instruction where flight controls are available to both pilots. The rules of this part are also not pertinent regarding instrum ent flight as our sUA are not instrum ent flight capable and will only fly in Visual Meteorological Conditions (VMC). **Equal level of safety**

– Relief from the rules associated with 14 CF R, part 91.109 will have no bearing on the com

pany’ s safe operations because the rules are not applicable to our sUA

. **Public benefit –**  Th ere is no benefit or loss to the public by relieving the com pany of com

pliance with the rules of this regulation. **S ummary** 

: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91.10 9 : “ Flight instruction; Sim ulated instrum ent flight and certain flight tests

. ” The rules of this part do not apply to Small Unm anned Aircraft (sUA) because the aircraft has no cockpit and cannot fly in instrum ent meteorological conditions. 

### 91.119 Minimum safe altitudesAerial Logistics NW LLC

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9 **Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:**  **(a) Anywhere.**  **An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.**  **(b) Over congested areas.**  **Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an a**  **ltitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.**  **(c) Over other than congested areas.**  **An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases,**  **the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.**  **(d) Helicopters, powered parachutes, and weight** **- shift** **- control aircraft.**  **If the operation is conducted without hazard to persons or property on the surface**  **— (1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or**  **(c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and**  **(2) A powered parachute or weight**  **- shift**  **- control aircraft may be operated at less than the**  **minimums prescribed in paragraph (c) of this section. Reason for the request** 

– 14 CFR, 91.119, “Minimum Safe A ltitudes ” as written is only pertinent to manned aircraft which with the exception of h elicopters, powered parachutes, and weight
-shift
control aircraft must operate above 500 feet above the surface. Relief from the rules as published will allow the com

pany to prepare a plan for operating our sUA in the safest m anner in order to mitigate risk to other aircraft, persons and property within the NAS or on the ground. **Extent of relief**

– Aerial Logistics NW LLC requests relief from the rules associated with this part and requests permission to mo dify operations to comply with the guidance offered in Advisory Circular 91
- 57

A , “Model Aircraft Operating Standards,” dated September 2, 2015

. **Equal level of safety**

– Aerial Logistics NW LLC intends to com ply with the guidance of AC 91
- 57A, “Model Aircraft Operating Standards ” which limits Unm anned Aircraft (UA) to 400 feet above the surface. This altitude lies below the minim umaltitudes delineated by Sec. 91.119 for all but helicopters, powered parachutes, and weight
-shift
- control aircraft. Per AC 91
- 57A , com pany pi lots will give way to m anned aircraft and check NOTAMs to avoid operations where our sUA might cause a hazard to them. **Public benefit –**  Th e benefit to relieving the com pany of the rules as published and establishm ent of the com pany’ s plan to operate their sUA will result in safer operations of our sUA above and around the public. **Summary**

: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR, 91.119, “Minim um Safe A ltitudes .” The rules of this part apply to ma nned aircraft, not Small Unm anned Aircraft (sUA) . The com pany plans to com

ply instead with the guidance o ther rule as it related to low level flight and with Advisory Circular 9 1
- 57 A dated September 2, 2015 . This AC limits maxim umaltitude of sUA to 400Aerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

10 feet above the surface and suggests ways to avoid operations near people, property, noise hazard areas and airports and otherwise operate sUA m ore safely

. 

### 91.121 A **ltimeter settings**  **(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating**  **— (1) Below 18,000 feet MSL, to**  **— (i**  **) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;**  **(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of a**  **n appropriate available station; or (iii) In the case of an aircraft not equipped with a radio, the elevation of the departure**  **airport or an appropriate altimeter setting available before departure; or (2) At or above 18,000 feet MSL, to 29.92**  **ʺ Hg.**  **(b) The lowest usable flight level is determined by the atmospheric pressure in the area of operation as**  **shown in the following table: Current altimeter setting**  **Lowest usable flight level 29.92 (or higher)**  **180 29.91 through 29.42**  **185 29.41 through 28.92**  **190 28.91 through 28.42**  **195 28.41 through 27.92**  **200 27.91 through 27.42**  **205 27.41 through 26.92**  **210 (c) To convert minimum altitude prescribed under §§91.119 and 91.177 to the minimum flight level, the**  **pilot shall take the flight level equivalent of the minimum altitude in feet and add the appropriate number**  **of feet specified below, according to the current reported altimeter setting: Current altimeter setting**  **Adjustment factor 29.92 (or higher)**  **None 29.91 through 29.42**  **500 29.41**  **through 28.92 1,000**  **28.91 through 28.42 1,500** Aerial Logistics NW LLC

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11 **28.41 through 27.92 2,000**  **27.91 through 27.42 2,500**  **27.41 through 26.92 3,000**  **Reason for the request**

– This regulation is not pertinent to our sUA as there is no altim eter onboard. **Extent of relief**

– Aerial Logistics NW LLC requests relief from the rules associated with 91.121
“ Altim eter settings. ” **Equal level of safety**

– There is no requirem ent for sUA pilots to have an altimeter onboard or to have an altitude function in its operation. But there is a statutory requirem ent for the sUA pilot to rem ain below 400 feet above the ground and to post a NOTAM before a flight

. A bsence of an altim eter on our sUA will have no negative bearing on safe and legal flight operations or to remain below the maxim um altitude of 400 feet above the surface . Most com pany operations are expected to take place at altitudes below 200 feet. Since the pilots of our sUA are FAA certificated pilots, operating at that low altitude an experienced pilot should be able to keep the sUA well below its maxim umaltitude. Operations above 200 feet above the surface will most likely be associated with work around tall towers. In the event of work near tall to wers, reference to aeronautical charts will allow the pilot to note the height of the towers in com parison to the altitude of the sUA in order to m aintain altitude below 400 feet. **Public benefit –**  Th ere is no benefit or loss to the public by relieving th e com pany of com

pliance with the rules of this regulation. **Summary**

: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91.1 21 : “ Altim eter settings.” The sUA operated by the com pany do not possess altim eters. Since they will not operate in the NAS above 400 feet , except by NOTAMs posted by the com pany before a flight there is no need to report their altitude to other aircraft. Altitude of the sUA will be determined by its pilot who is also an FAA certificated pilot. Since m ost com pany opera tions will take place within 200 feet of the surface their experience should allow them to keep the sUA well below 400 feet. Work at altitudes above 200 feet will m ost likely be associated with tall towers. Reference to aeronautical charts will allow the p ilot to estimate altitude of the sUA in relation to tower height. 

### 91.151 Fuel requirements for flights in VFR conditions **(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal**  **cruising speed —**  **(1) During the day, to f ly after that for at least 30 minutes; or** Aerial Logistics NW LLC

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12 **(2) At night, to fly after that for at least 45 minutes. (b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast**  **weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal**  **cruising speed, to fly after that for at least 20 minutes. Reason for the request** 

– Th e rules associated with part 91.151 “ Fuel requirements for flights in VFR conditions ” are not pertinent to the com pany’ s sUA. The com

pany sUA carry no flammable liquids/fuel. The com

pany cannot com

ply with the rule because our sUA are electrically powered with between 20 and 30 minutes of actual battery life/ operating tim e available. This is le ss than the mi nim umfuel required as a reserve during a day VFR flight in a manned aircraft. **Extent of relief**

– Aerial Logistics NW LLC requests relief from the rules associated “ Fuel requirements for flights in VFR conditions .” **Equal level of safety**

– Exem ption from the rules associated with part 91.151 will have no bearing on safe operation because the com pany’ s sUA operate on batteries. Safety will be enhanced in our operations because the sUA are required to rem ain within line of sight of the pilo t and consequently well within range of their takeoff point at all tim es. Because of the short duration of their battery charge and 1 kilom eter range of its radio controls, our sUA will not be engaged in cross
- country operations. The com

pany will continue to plan for VFR flight checking weather and winds, but will not conduct any cross
- country operations

. All flights will be safely terminated with a reserve battery power of no less than 25% of their maxim um charge. **Public benefit –**  Th ere is no benefit or loss to the public by relieving the com pany of com

pliance with the rules of this regulation. **Summary**

: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91.15 1 : “Fuel requirem ents for flights in VFR conditions” because the rules are not applicable to their sUA operations. The com

pany will continue to plan for VFR flight checking weather and winds, but will not conduct any cross
- country operations because t he short range of control and the short duration of the sUA battery charge does not permit it. All flights will be safely terminated with a reserve battery power of no less than 25% of their m axim um charge. 

### 91.405 Maintenance required **Each owner or operator of an aircraft**  **— (a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between**  **required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter;**  **(b) Shall ensure that maintenance personnel make appropriate entries in the aircraft maintenance records indicating the aircraft has been approved for return to service;** Aerial Logistics NW LLC

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13 **(c) Shall have any inoperative instrument or item of equipment, permitted to be inope rative by**  **§91.213(d)(2) of this part, repaired, replaced, removed, or inspected at the next required inspection; and**  **(d) When listed discrepancies include inoperative instruments or equipment, shall ensure that a placard has been installed as required by**  **§43.11 of this chapter. Reason for the request** 

– This regulation is not pertinent to sUA because they are not manufactured in accordance with 14 CFR airworthiness standards. The com pany sUA do not have any part 43 FAA required inspections. Neither do they have any flight instrum ents that require inspection or placards when they fail. **Extent of relief**

– Aerial Logistics NW LLC requests relief from the rules associated with 91.405
“ Maintenance required

. ” **Equal level of safety**

– The ma nufacturer of the company’ s sUA provide guidance for maintaining them in the operator’

s manual provided when purchasing the sUA. In the interest of safety of flight, efficient operation and preservation of com pany assets the com

pany sUA will be maintaine d to manufacturer’

s standards. The manufacturer provides a troubleshooting guide, a 24 /7 hotline for assistance in maintaining the sUA , and deep
-level repair at their US facility. Any com pany sUA t

hat has undergone maintenance or alterations that affect s the operation or flight characteristics will undergo a functional test flight prior to conduct f urther op erations under this exem ption. Functional test flights will be conducted by a pilot with a visual observer and shall remain at least 500 feet from

other people in such a manner so as to not pose an undue hazard to persons and property. **Public benefit –**  Th ere is no benefit or loss to the public by relieving the com pany of com

pliance with the rules of this regulation. **Summary**

: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91. 4 05 : “ Maintenance required. ” The com

pany sUA is not a passenger carrying aircraft and is not manufactured to 14 CFR airworthiness standards. Maintenance is provided by the owner utilizing the manufacturer’ s instruction m anual, a 24/7 hotline with the com pany and if necessary advanced maintenance pro vided at the manufacturer’ s United States facility. 

### 91.407 Operation after maintenance **(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless**  **— (1) It has been approved for return**  **to service by a person authorized under §43.7 of this chapter; and**  **(2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has been made.** Aerial Logistics NW LLC

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14 **(b) No person may carry any person (other than crewmembers) in an aircraft that has been maintained,**  **rebuilt, or altered in a manner that may have appreciably changed its flight characteristics or substantially affected its operation in flight until an appropriately rated pilot with at least a private pilot certificate flies**  **the airc raft, makes an operational check of the maintenance performed or alteration made, and logs the**  **flight in the aircraft records. (c) The aircraft does not have to be flown as required by paragraph (b) of this section if, prior to flight,**  **ground tests, inspe ction, or both show conclusively that the maintenance, preventive maintenance,**  **rebuilding, or alteration has not appreciably changed the flight characteristics or substantially affected the flight operation of the aircraft.**  **Reason for the request**

– This regulation is not pertinent to the com pany ’s sUA as it is not manufactured to 14 CFR, Part 43 or Part 21 airworthiness standards

. The aircraft is “unmanned” so rules pertinent to the carriage of passengers and flight by a pilot after repair or alterat ion are not applicable to the sUA and the com pany’ s operation. **Extent of relief**

– Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91. 407, “Operation after maintenance

. ” **Equal level of safety**

– The level of safety assured by this regulation is unaffected by the com pany’ s relief from

its rules because the sUA will be m aintained to manufacturers ’ standards by the com pany
. In the interest of safety, effectiveness of the equipm ent and preservation of com pany assets the com

pany’ s aircraft will be maintained and safely operated to m eet manufacturer’ s standards. In the interest of safety of flight, efficient operation and preservation of com pany assets a ny com pany sUA t

hat has undergone maintenance or alterations that affect s the operation or flight characteristics will undergo a functional test flight prior to conducting further op erations under this exem ption. Functional test flights will be conducted by a pilot with a visual observer and shall remai n at least 500 feet from

other people in such a manner so as to not pose an undue hazard to persons and property. **Public benefit –**  Public assets and m anpower will be preserved because there is no requirem ent for an FAA maintenance inspector to examine Part 43 maintenance perform ed by an FAA certificated Airfram e and Power

- plant mechanic. Even so, the FAA can continue to m onitor and check the maintenance perform ed by the com pany as desired. **Summary**

: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR part 91. 407, “Operation after maintenance” because it is not applicable to sUA. Since the sUA is unmanned, rules referring to operation of the aircraft with a pilot or passenger onboard are not applicable. Safety of flight will require post

-ma intenance check flights be conducted in such a way as to avoid persons or property. 

### 91.409 InspectionsAerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

15 **(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months,**  **it has had —**  **(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or**  **(2) An inspection for the issuance of an airworthiness certificate in accordan ce with part 21 of this**  **chapter. No inspection performed under paragraph (b) of this section may be substituted for any inspection**  **required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “**  **annual” inspection in the required maintenance records. (b) Except as provided in paragraph (c) of this section, no person may operate an aircraft carrying any**  **person (other than a crewmember) for hire, and no person may give flight instruction for hire i n an aircraft**  **which that person provides, unless within the preceding 100 hours of time in service the aircraft has received an annual or 100**  **- hour inspection and been approved for return to service in accordance with part**  **43 of this chapter or has received an inspection for the issuance of an airworthiness certificate in**  **accordance with part 21 of this chapter. The 100 -**  **hour limitation may be exceeded by not more than 10 hours while en route to reach a place where the inspection can be done. The excess time**  **used to reach a place where the inspection can be done must be included in computing the next 100 hours of time in**  **service. (c) Paragraphs (a) and (b) of this section do not apply to**  **— (1) An aircraft that carries a special flight permit, a current experi**  **mental certificate, or a light -**  **sport or provisional airworthiness certificate;**  **(2) An aircraft inspected in accordance with an approved aircraft inspection program under part 125 or 135 of this chapter and so identified by the registration number in the o**  **perations specifications of the certificate holder having the approved inspection program;**  **(3) An aircraft subject to the requirements of paragraph (d) or (e) of this section; or (4) Turbine**  **- powered rotorcraft when the operator elects to inspect that rotorcraft in accordance**  **with paragraph (e) of this section. (d)**  **Progressive inspection. Each registered owner or operator of an aircraft desiring to use a progressive**  **inspection program must submit a written request to the FAA Flight Standards district office having jurisdiction over the area in which the applicant is located, and shall prov**  **ide —**  **(1) A certificated mechanic holding an inspection authorization, a certificated airframe repair station, or the manufacturer of the aircraft to supervise or conduct the progressive inspection;**  **(2) A current inspection procedures manual available and r eadily understandable to pilot and**  **maintenance personnel containing, in detail —**  **(i) An explanation of the progressive inspection, including the continuity of inspection responsibility, the making of reports, and the keeping of records and technical referen**  **ce material;**  **(ii) An inspection schedule, specifying the intervals in hours or days when routine and detailed inspections will be performed and including instructions for exceeding an**  **inspection interval by not more than 10 hours while en route and for cha nging an**  **inspection interval because of service experience; (iii) Sample routine and detailed inspection forms and instructions for their use; and** Aerial Logistics NW LLC

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**(iv) Sample reports and records and instructions for their use; (3) Enough housing and equipment for necessar** **y disassembly and proper inspection of the aircraft; and (4) Appropriate current technical information for the aircraft.**  **The frequency and detail of the progressive inspection shall provide for the complete inspection of the aircraft within each 12 calenda**  **r months and be consistent with the manufacturer's recommendations, field service experience, and the kind of operation in which the aircraft is engaged. The progressive inspection**  **schedule must ensure that the aircraft, at all times, will be airworthy and will conform to all applicable FAA**  **aircraft specifications, type certificate data sheets, airworthiness directives, and other approved data. If the progressive inspection is discontinued, the owner or operator shall immediately notify the local FAA**  **Flight Standards district office, in writing, of the discontinuance. After the discontinuance, the first annual**  **inspection under §91.409(a)(1) is due within 12 calendar months after the last complete inspection of the aircraft under the progressive inspection. T**  **he 100 -**  **hour inspection under §91.409(b) is due within 100 hours after that complete inspection. A complete inspection of the aircraft, for the purpose of determining**  **when the annual and 100 -**  **hour inspections are due, requires a detailed inspection of the ai rcraft and all its**  **components in accordance with the progressive inspection. A routine inspection of the aircraft and a detailed inspection of several components is not considered to be a complete inspection.**  **(e) Large airplanes (to which part 125 is not a**  **pplicable), turbojet multiengine airplanes, turbo**   ** propeller** **- powered multiengine airplanes, and turbine**  **- powered rotorcraft.**  **No person may operate a large airplane, turbojet multiengine airplane, turbo**  **- propeller**  **powered multiengine airplane, or turbine**  **- power**  **ed rotorcraft unless the replacement times for life -**  **limited parts specified in the aircraft specifications, type data sheets, or other documents approved by the Administrator are**  **complied with and the airplane or turbine -**  **powered rotorcraft, including the a irframe, engines,**  **propellers, rotors, appliances, survival equipment, and emergency equipment, is inspected in accordance with an inspection program selected under the provisions of paragraph (f) of this**  **section, except that, the owner or operator of a tur bine**  **- powered rotorcraft may elect to use the**  **inspection provisions of §91.409(a), (b), (c), or (d) in lieu of an inspection option of §91.409(f). (f)**  **Selection of inspection program under paragraph (e) of this section. The registered owner or**  **operator of each airplane or turbine**  **- powered rotorcraft described in paragraph (e) of this section**  **must select, identify in the aircraft maintenance records, and use one of the following programs for the inspection of the aircraft:**  **(1) A continuous airworthiness insp ection program that is part of a continuous**  **airworthiness maintenance program currently in use by a person holding an air carrier operating certificate or an operating certificate issued under part 121 or 135 of this**  **chapter and operating that make and mod el aircraft under part 121 of this chapter or**  **operating that make and model under part 135 of this chapter and maintaining it under §135.411(a)(2) of this chapter.**  **(2) An approved aircraft inspection program approved under §135.419 of this chapter and cur**  **rently in use by a person holding an operating certificate issued under part 135 of this chapter.**  **(3) A current inspection program recommended by the manufacturer. (4) Any other inspection program established by the registered owner or operator of that**  **a irplane or turbine**  **- powered rotorcraft and approved by the Administrator under** Aerial Logistics NW LLC

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**paragraph (g) of this section. However, the Administrator may require revision of this inspection program in accordance with the provisions of §91.415.**  **Each operator shall includ e in the selected program the name and address of the person**  **responsible for scheduling the inspections required by the program and make a copy of that program available to the person performing inspections on the aircraft and, upon**  **request, to the Adminis trator.**  **(g) Inspection program approved under paragraph (e) of this section.**  **Each operator of an airplane or turbine**  **- powered rotorcraft desiring to establish or change an approved inspection program under**  **paragraph (f)(4) of this section must submit the p rogram for approval to the local FAA Flight Standards**  **district office having jurisdiction over the area in which the aircraft is based. The program must be in writing and include at least the following information:**  **(1) Instructions and procedures for the conduct of inspections for the particular make and model**  **airplane or turbine -**  **powered rotorcraft, including necessary tests and checks. The instructions and procedures must set forth in detail the parts and areas of the airframe, engines, propellers, rotors** **, and appliances, including survival and emergency equipment required to be inspected.**  **(2) A schedule for performing the inspections that must be performed under the program expressed in terms of the time in service, calendar time, number of system operat**  **ions, or any combination of these.**  **(h) Changes from one inspection program to another.**  **When an operator changes from one inspection program under paragraph (f) of this section to another, the time in service, calendar times, or cycles of**  **operation accumul ated under the previous program must be applied in determining inspection due times**  **under the new program. Reason for the request** 

– This regulation is only pertinent for manned aircraft build under 14 CFR regulations. **Extent of relief**

– Aerial Logistics NW LLC seeks relief from the rules of 14 CFR, Part 91.409
“ Inspections .” **Equal level of safety**

– The level of safety assured by this regulation is unaffected by the com pany’ s relief from

its rules because the sUA will be maintained to manufacturers’ standards by the com pany. In the interest of safety, effectiveness of the equipm ent and preservation of com pany assets the com

pany’ s aircraft will be maintained and safely operated to m eet manufacturer’ s standards. In the interest of safety of flight, efficient operation and preservation of com pany assets a ny com pany sUA t

hat has undergone maintenance or alterations that affect s the operation or flight characteristics will undergo a functional test flight prior to conducting further op erations under this exem ption. Functional test flights will be conducted by a pilot with a visual observer and shall remai n at least 500 feet from

other people in such a manner so as to not pose an undue hazard to persons and property. **Public benefit –**  Public assets and m anpower will be preserved because there is no requirem ent for an FAA maintenance inspector to examine Part 43 maintenance perform ed by an FAA certificatedAerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

18 Airfram e and Power plant mechanic. Even so, the FAA can continue to m onitor and check the maintenance perform ed by the com pany as desired. **Summary**

: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR, Part 91.409 “ Inspections .” because it is not applicable to sUA. Since the sUA is unmanned, rules referring to operation of the aircraft with a pilot or passenger onboard are not applicable. Safety of flight and will require post
maintenance check flights be conducted in such a way as to av oid persons or property. 

### 91.417 Maintenance records **(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:**  **(1 ) Records of the maintenance, preventive maintenance, and alteration and records of the 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 of an aircraft. The**  **records must include —**  **(i) A description (or reference to data acceptable to the Administrator) of the work performed; and**  **(ii) The date of completion of the work performed; and (iii) The signature, and certificate numb**  **er of the person approving the aircraft for return to service.**  **(2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller, and each rotor.**  **(ii) The current status of life -**  **limited parts of each airframe, engine, propeller, rotor, and**  **appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to**  **be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, includin**  **g the time since the last inspection required by the inspection program under which the aircraft and its appliances**  **are maintained. (v) The current status of applicable airworthiness directives (AD) and safety directives**  **including, for each, the method of compliance, the AD or safety directive number and**  **revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.**  **(vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to**  **the airframe and currently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed:**  **(1 ) The records specified in paragraph (a)(1) of this section shall be retained until the work is**  **repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with**  **the aircraft at the time the aircraft is sold.**Aerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

19 **(3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be ret**  **ained until the defects are repaired and the aircraft is approved for return to service. (c) The owner or operator shall make all maintenance records required to be kept by this section available**  **for inspection by the Administrator or any authorized repre sentative of the National Transportation Safety**  **Board (NTSB). In addition, the owner or operator shall present Form 337 described in paragraph (d) of this section for inspection upon request of any law enforcement officer.**  **(d) When a fuel tank is installe d within the passenger compartment or a baggage compartment pursuant to**  **part 43 of this chapter, a copy of FAA Form 337 shall be kept on board the modified aircraft by the owner or operator.**  **Reason for the request**

– This regulation is only pertinent for manned aircraft built under 14 CFR regulations. **Extent of relief**

– Aerial Logistics NW LLC requests relief from the rules associated with 14 CFR, Part 91.417

, “ Maintenance records .” **Equal level of safety**

– The level of safety assured by this regulation is unaffected by the com pany’ s relief from

its rules because the sUA will be maintained to manufacturers’ standards by the com pany. In the interest of safety, effectiveness of the equipm ent and preservation of com pany assets the com

pany’ s aircraft will be maintained and safely operated to m eet manufacturer’ s standards. In the interest of safety of flight, efficient operation and preservation of com pany assets a ny com pany sUA t

hat has undergone maintenance or a lterations that affect s the operation or flight characteristics will undergo a functional test flight prior to conducting further op erations under this exem ption. Functional test flights will be conducted by a pilot with a visual observer and shall remain at least 500 feet from

other people in such a manner so as to not pose an undue hazard to persons and property. **Public benefit –**  Public assets and m anpower will be preserved because there is no requirem ent for an FAA maintenance inspector to examine Part 43 maintenance perform ed by an FAA certificated Airfram e and Power plant mechanic. Even so, the FAA can continue to m onitor and check the maintenance perform ed by the com pany as desired. **Summary**

: Aerial Logistics NW LLC seeks relief from the rules of 14 CFR, Part 91.4 17 “Maintenance records,” because it is not applicable to sUA. Since the sUA is unmanned, rules referring to operation of the aircraft with a pilot or passenger onboard are not applicable. Safety of flight and will require post

-ma intenance check flights be conducted in such a way as to avoid persons or property. 

### D **escribe the design and operational characteristics for the type(s) of UA S the**  **company intend**  **s to ope**  **rate**
**.** The company intends to operate Yunee c ‘Typhoon Q500 / 500H , ’ Yuneec ‘Tornado H920,’ The DJI ‘Phantom , 

### ’ the 

### DJI ‘Inspire , 

### ’ Sensefly ‘Ebee Ag,’ Precision Hawk ‘Landcaster Platform,’ a 

### nd the 3D Robotix ‘IRIS.’ Because these Unmanned AerialAerial Logistics NW LLC

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### Systems weigh less than 55 pounds each ( including payload

) they are classified as Small Unmanned Aircraft (sUA). T hese models are “quadcopters” with four propellers driven by electric m otors or ‘hexcopters’ driven by eight propellers

. We also intend to utilize two types of fixed wing sUA driven by one electric driven propeller. The Quadcopter and Hexcopter has a set of skid type landing gear for vertical landings. The fixed wing sUA have a fixed set for landing gear that will aid in rol l
- on landings. The Quadcopter and the Hexcopter have similar flight characteristics and performance similar to a he licopter and the fixed wing sUA flight characteristics would model most manned fixed wing airplanes

. T hey are remotely controlled by a standard 10 channel radio control device common to recreational radio controlled aircraft. Sensors of various types can be attached to a pilot controlled gimbal mount on the underside of the sUA. The company will use remote ly controlled digital cameras for the type the sUA is designed to carry, such as the “ gopro HERO4. ” 

### A **ircraft performance and limitations**
**.** The company operates seven models of sUA. General operating limitations listed here are optimal and are representative of capabilities that can be met by all seven models. Some models may perform better than the specifications listed here i.e. have longer operating tim es on a single battery charge, operate at higher ambient tem peratures, higher altitudes above sea level or m aneuver at fas ter rates. 

### Battery charge duration depend s on the flight’

s altitude above sea level. M aximum duration of flight below 3000 feet above mean sea level (MSL) is between 15

– 45 minutes with a full battery charge depending on sUA model , with the DJI Phantom noting a 30 minute maximum flight time in the same operating regime

. Flights of 11 minutes have been documented by users at the service ceiling altitude. Maximum airspeed allowed for sUA is 100 mph

. Maximum speed of our sUA are 35 mph

. Operating temperatures : - 10°C to 4 0°C (80°C for the ‘ Typhoon ’ ) Maximum bank angle : 35° at 300° per second Maximum yaw rate : 150° per second Maximum rate of climb : 1200 feet per minute ( fpm ) Maximum rate of descent: 400 fpm Service ceiling : 12,000 feet MSL @
- 9°C Maximum legal altitude : 400 feet AGL (above ground level) Maximum controllable range from the pilot: 1000m , ( 0.6 miles) 

### Provide a **ircraft loading information in as much detail as possible.**Aerial Logistics NW LLC

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### All models of sUA operated by the company are equipped with a removable camera which when attached, brings the sUA to the maximum gross weight reflected below. (

All weights are based on a grams to pounds conversion ). DJI ‘ Inspire ’

– 6.5 lbs. DJI ‘ Phantom ’

– 2.8 lbs. 3D Rob ot

ix ‘ Ir is ’

– 2.9 lbs. Yuneec ‘ Typhoon ’

– 3.7 lbs. Yuneec ‘Tornado’

– 11 lbs. Sensefly ‘Ebee Ag’

– 1.25 lbs. Precision Hawk ‘Landcaster’

– 7.5 lbs. All aircraft will perform normally at the service ceiling at maximum gross weight. **O perating procedures**  will vary based on the job , location, custom er and the sUA used to com plete it. But procedures use d that are comm on to every flight include conduct of a com pany 

### Site Assessment, Risk Management Assessment and Safety Mitigation Plan

. These documents are included later in this document. These documents describe in detail how a safe and legal company flight is to be planned, performed , terminated and recorded. Each job will be conducted by a minimum of one FAA certificated and company trained pilot and one company trained visual observer. After conducting the 

### Site Assessment and 

### Risk Management Assessment, the pilot and observer will work together to produce a 

### S afety Mitigation Plan . This document will serve as a flight plan for the conduct of the job. All of t hese documents will be turned over to and maintained by company management at the completion of the job to document flight time, the planning for the flight and the lessons learned in performing the job . These lessons will 

### be circulated throughout the company and covered in training in order to increase the level of safety and efficiency of the operation. Company perso nnel are trained to either not launch , discontinue or terminate a flight immediately whenever any unplanned hazard or risk develops. Flight will not be initiated or continued until the identified risk or haz ard has been mitigated or eliminated. Flying safe ly is the most important element of our business. No job is worth risking injury to people , damage to property over which we fly or damage or loss of our equipment

. 

### Petitioners should **describe any procedures they** 

**would implement to ensure that**  **the UA S is in a condition for safe flight,**  **such as :** Aerial Logistics NW LLC

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### P **re -**  **flight inspections**

– A careful preflight inspection will be conducted on company aircraft before each flight by using guidance in the manufacturer ’ s operator’s manual. During Pre
-flight inspections the pilot will look for mechanical or electronic defects in order to insure the sUA is in good condition and safe for flight. T he pilot will check radio controls, structural members, landing gear and propellers for improper function, damage and wear. Company operating procedures require that the pilot conduct performance and power checks (such as hover in and out of ground effect checks) prior to departing the takeoff area for a flight. **M aintenance and repair** 

– Ae rial Logistics NW LLC 

### will use the manufacturer’ s recommended component maintenance . Since these manuals are limited to owner maintenance the company will refer to the manufacturer’ s help line for advice on overhaul, replacement, inspection, and component life limits to repair or replace parts and keep the aircraft in good repair

. In the interest of safety, effectiveness of the equipment and preservation of company assets the company’ s aircraft will be maintained and safely operated to meet manufacturer’ s s tandards

. Wh ere covered by owner’s manual instructions, r epair and maintenance shall be completed by the company . Higher level maintenance will be completed with reference to the manufacturer’

s help line to complete the repair in
-house or by returning th e sUA to an authorized repair facility. Any company sUA that has undergone maintenance or alterations that affects the operation or flight characteristics will undergo a functional test flight prior to conducting further operations under this exemption. Functional test flights will be conducted by a pilot with a visual observer and shall remain at least 500 feet from other people in such a manner so as to not pose an undue hazard to persons and property. **Maintenance Manua ls** 

– The company owner’ s manual that comes with each sUA contains procedures for troubleshooting and maintaining the aircraft. These will serve as the company maintenance manuals. A record of flights with discrepancies found and type of repair performed will be kept in the sUA logbook as a company record. 

### Describe the **Radio Frequency (RF) spectrum used for control of the UA** **S and associated equipment that is part of the UA** **S (i.e., sensors, cameras, etc.)** All company aircraft onboard systems and remote radio controllers comply with FCC requirements for model (radio cont rolled) aircraft

. The PIC inputs to the aircraft are maintained by standard 10 channel remote controls operating on the 2.4GHz RC band. Video downlink is achieved on the 5.8GHz band. Documentation of this compliance is printed in the operator ’ s manuals for each aircraft.Aerial Logistics NW LLC

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### D **escribe the qualifications required of any PIC(s) w ho will be directly**  **respon sible**  **for the operation of the u AS** 
**.** 14 CFR, Sec. 91.3 will govern the authority of the company pilots. **Sec. 91.3 —**  **Responsibility and authority** 

**of the pilot in command.**  (a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft. Under this grant of exemption, a company PIC must hold a US Federal Aviation Administration (FAA) pilot certificate either recreational, private, commercial or airline transport

. The PIC must possess a current US driver’ s license and/or a current FAA Class I, II or III medical certificate. The sUA must be op erated 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. The pilot must also meet the flight review requirements specified in 1 4 CFR § 61. 56 in an aircraft in which the pilot is rated on his or her pilot certificate. The company shall not permit any PIC to operate unless the pilot demonstrates the ability to safely operate the uAS in a manner consistent with how the u AS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PICs must have at least 5 hours total flight time in Unmanned Aircraft (UA) and 5 ho urs in the type uAS the company flies before conducting company business operation flight s. PICs must log flight time in a manner consistent with 14 CFR § 61.51(b). Flights shall be logged along with their purpose, be it company operations or for the purposes of training the PICs and V

isual O bserver

s (VO) , or for determining the PIC’ s ability to safely operate the s UA

. T raining operations may only be conducted during dedicated training sessions. During training, proficiency, and experience
-building f lights, all persons not essential for flight operations are considered non
- participants, and the PIC must operate the s UA

.Aerial Logistics NW LLC

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### Describe the qualifications **and roles required of any**  **Visual Observer wh**  **o will be directly**  **responsible for the operation of the UA S**  **and any**  **applicable training related to the operation;**  At least one visual observer is required to conduct any sUA company flight. This person shall have corrected or uncorrected sight in both eyes and be capable of clear verbal communication in the En glish language

. Except for training flights, Visual Observers (VO) must have received at least one hour of ground training to include FAA sUA requirements and regulations and company procedures included in this application ; and one hour of training with a PIC flying the sUA before acting as an observer on company flights. VO t raining operations may only be conducted during dedicated training sessions. The role of the VO is to assist the pilot in keeping the sUA in sight an d clear of haz ards and obstructions over the flight planned route. The VO should also: maintain direct line
of
- sight observations unaided by anything but corrective lenses; help the pilot conduct pre -flight assessments; identify and avoid or otherwise remediate haz ards prior to and during the flight; find and direct the pilot to safe and appropriate landing sites as required ; assist the pilot with any task that would cause the pilot to take a hand off of the flight control

s . The VO will call for the pi lot to land the sUA and postpone or discontinue the flight whenever he

/she is unable to see the sUA or continue his/her duties while the sUA is airborne. 

### Petitioners should describe the medical standards and certification of the PIC(s) **directly respon**  **sible for the operation of the sUA**

. The PIC must possess a current US driver’ s license and/or a current FAA Class I, II or III medical certificate. The sUA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires th e PIC to be able to use human vision unaided by any device other than corrective lenses

. 

### Regarding the Operation of the Unmanned A **ircraft :**  **D escribe their intended UA** **S operation(s).** Aerial Logistics NW LLC 

### intends to utilize s UA to safely conduct commercial photography and video operations for public, private and commercial use including but not limited to : inspection of residential, commercial, and industrial real estate for realty companies; assist ing engineering firms or agencies and the energy industry in conducting surveysAerial Logistics NW LLC

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### and inspections, assisting wildlife and agriculture businesses or agencies searches and surveys; aiding public agencies in search and rescue operations ; providing aerial videography for TV production companies and providing training for pilots and observers in the operation of sUA.

. 

### D **escribe how the proposed operation(s) would not adversely affect safety**  **and how** **they**

**would provide a level of safety at least equivalent to that provided by**  **the rule from which exemption is sought.** T he FAA has found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifications described by the petitioner and carrying no passengers or crew, rather than a manned aircraft of significantly greater proportions, carrying crew in addition to flammable fuel, gives the FAA good cause to find that the UAS operation enabled by this exemption is in the publ ic interest. Likewise it is safer to us e sUA to conduct many of the requested operations tha n to rely on a helicopter to hover over critical infrastructure, or ask a person to climb on and/or photograph a bridge, walk over haz

ardous terrain, climb a flare stack or other piece of equipment that can easily be reached by sUA. 

### Describe plans to implement clearly **defined operational borders and procedures to ensure public safety, w**  **hich includes persons and property both in the air and**  **on the ground.** Twenty
-f our hours prior to any flight the company will submit a Notice to Airmen (NOTAM) to alert air traffic to the location, time and maximum altitude of our operation. Immediately p rior to flight the company pilot will do a detailed survey of the site of the intended flight and the surrounding area utilizing the company Site Assessment, Risk Management Assessment and Safety Mitigation Plan. If haz ards or safety risks are noted during the initial Site Assessment, these will be mitigated or eliminated before fli ght is conducted. A s necessary , signs and/or observers will be placed at points along the sUA intended flight path to keep it clear of people, vehicles and other obstructions and hazards. Observers noting a haz ard will notify the pilot who will immediately take the appropriate action to mitigate that risk, which may include re
- direction of the sUA to a safe area where the flight can be terminated until the risk is mitigated. 

### Specify **the proposed maximum operating speed and altitude** Regulations limit sUA to 100 mph and 400 feet above the surface. No company sUA can travel faster than 50 mph. Pilots insure that the job can be safely and legally completed at altitudes less than th e maximum altitude of 400 feet above the surface.Aerial Logistics NW LLC

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### Describe minimum flight vis **ibility and distance from clouds for operation(s).**  Aerial Logistics NW LLC 

### intends to use the guidance of 14 CFR, Part 91.155 (b) (1) for flight visibility and cloud clearance minimums in Class G airspace. (b) Class G Airspace. Notwithstanding the provisions of paragraph (a) of this section, the following operations may be conducted in Class G airspace below 1,200 feet above the surface: (1) Helicopter. A helicopter may be operated clear of clouds if operated at a speed that allows the pilot adequat e opportunity to see any air traffic or obstruction in time to avoid a collision. Flights in other airspace as cleared by a Certificate of Authorization for specific flights will utilize the most conservative guidelines of Sec. 91. 1 55 used for airplanes as follows: **Sec. 91.155**
**— Basic VFR weather minimums.**  (a) Except as provided in paragraph (b) of this section and §91.157, no person may operate an aircraft under VFR when the flight visibility is less, or at a distance from clouds that is less, than that prescribed for the corresponding altitude and class of airspace in the following table:

**Airspace Flight visibility**  **Distance from clouds**
Class A
- **NOT APPLICABLE TO sUA** Not Applicable Not Applicable. Class B 3 statute miles Clear of Clouds.
Class C 3 statute miles 500 feet below. 1,000 feet above. 2,000 feet horizontal.
Class D 3 statute miles 500 feet below. 1,000 feet above. 2,000 feet horizontal.
Class E:Aerial Logistics NW LLC

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27 Less than 10,000 feet MSL 3 statute miles 500 feet below. 1,000 feet above. 2,000 feet horizontal At or above 10,000 feet MSL **NOT APPLICABLE TO sUA** 5 statute miles 1,000 feet below. 1,000 feet above. 1 statute mile horizontal. Class G: 1,200 feet or less above the surface (regardless of MSL altitude) Day, except as provided in §91.155(b) 1 statute mile Clear of clouds. Night, except as provided in §91.155(b) **NOT APPLICABLE TO sUA** 3 statute miles 500 feet below. 1,000 feet above. 2,000 feet horizontal. More than 1,200 feet above the surface but less than 10,000 feet MSL Day 1 statute mile 500 feet below. 1,000 feet above. 2,000 feet horizontal. Night **NOT APPLICABLE TO sUA** 3 statute miles 500 feet below. 1,000 feet above. 2,000 feet horizontal. More than 1,200 feet above the surface and at or above 10,000 feet MSL 5 statute miles 1,000 feet below. 1,000 feet above. 1 statute mile horizontal.


### D **escribe potential hazards and safety mitigations associated with these**  **proposed conditions. Describe**  **in detail the Risk A**  **naly sis of the site so that the**  **planned operation can be comple ted safely.**  Aerial Logistics NW LLC 

### has a comprehensive plan to identify and either mitigate or eliminate hazards before a flight is conducted. (see next paragraph) The plan also calls on the pilot and observer to accommodate unexpected hazards. Before and then after a flight the pilot andAerial Logistics NW LLC

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28 

### observer work

s together to plan and then record the flight using the company’ s Site Assessment

, Safety Survey

, Safety Haz

ard M itigation Plan

. 

### The Site A

**ssessment , Risk Management Assessment and Safety Mitigation Plan**  a re designed to help the pilot evaluate the planned job and assess the risks at the site and the surrounding area where the sUA will be flown. These tools will allow com pany pilots and managem ent to insure all flights are conducted safely and in accordance with regulations and guidance from

the FAA. They will also act as tools to im prove training and day

- to
- day operations

. Safety in com

pany operations will im prove by passing on the lessons that are learned at each job.Aerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

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# Site **As sessment**  **Date : _** 

**_______________________**

**Pilot :**  **Observer :**  **Job Location :**  **(address, latitude/longitude and/or description).**



### A **Notice to A irmen (NOTA**  **M)** must be filed 24 hours before the flight is made. **NOTE! You may not fl**  **y a drone**  **:**

 From a moving vehicle or vessel.
 N ear military or federal facilities, certain stadiums (see NOTAMs/TFRs) , emergency services vehicles or stations, power plants, dams, electric substations or industrial complexes.
 In a Temporary Flight Restricted area (TFR) or Prohibited Area.
 N ear wind farms or oil refineries without permission.
 N ear The Disney resorts or inside the W ashington DC restricted zones and other Special Use airspace

.  Between sunset and sunrise ( i.e., no night operations )

.  Wi thin 5 miles of a n airport unless a Certificate of Authorization is issued for the operation by an FAA Flight Standards District Office.Aerial Logistics NW LLC

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### Prior to conducting any **flight,** T he pilot and observer shall walk the site or otherwise evaluate the job site. If this is impossible or ability to walk part of the site is limited , the pilot and observer shall walk to all points around the site from which they shall observe and control the drone. During the site survey the following factors will be considered. ** Be sure to note other factors n ot listed that may affect or detract from the safe and efficient completion of the job. **Factors to note at the job site:**
 Altitude of the site above sea level (Density Altitude)
 Ambient temperature
 W eather (cloud type s & height, horizontal visibility and wind direction, velocity and gusts , presence of rain, thunderstorms, fog or phenomena that will limit visual observation. )
 Air traffic
 People, animals or livestock in the open  Birds (especially in flocks and migratory birds like geese, ducks, doves , etc. ).
 Structures or property that could be damage d if struck by our drone
 Noise sensitive areas  Other sensitive areas like cemeteries , historical sites , wildlife refuges, etc.
 Drone prohibited areas like federal or military facilities, power plants, electric substations, dams, national parks, emergency services and industrial complexes

.  Wi res, antennas, towers and other o bstructions to the drone’s flight path
 Roads & Type and frequency of v ehicular traffic
 Presence of c onstruction or farm equipment and persons
 Condition of the terrain
 Ponds, streams and other bodies of water
 Height and types of vegetation
 The f light path and its traffic ability (C an you walk it?)
 Safety Area along the intended flight path
 Emergency L anding sites **Other factors I saw during my site assessment are listed here:** Aerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

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### Use this space to map the area and hazards y**ou noted during your assessment.** Aerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

32



# Risk Management **As sessment** 
**Date:________________________**
**Pilot :**  **Flight Time logged on**  **this job:**

**________________ (post this upon ending the flight)**  **Observer :**  **Job Location :**  **(address, latitude/longitude and/or description).**



### Ad **dress/Location:**

**The purpose of the Risk Management A**  **ssessment** is to document your evaluation of the job site and record the information you need to plan a safe and effective flight. The information you record will help us to plan safe flights and train others based on the flight you conduct. Use your “site assessme nt” and this “risk management assessment” to create a “mitigation plan” to be submitted to the company for each job you do. Note the hazards and write down you r plan to mitigate them. If a risk cannot be effectively and safely mitigated, DO NOT CONDUCT THE FLIGHT !Aerial Logistics NW LLC

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33Aerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

34 

### Date:________________________ 

# PREFLIGHT RISK A**SSESSMENT CHECKLIST Starting the day** 

**before the flight a nsw**  **er the following questions and re**  **** **check the day**

**of the flight:** Has a NOTAM been filed 24 hours or more before this flight? If not, cancel the flight until the requirement is met. Has permission of the land/property owners around the site been obtained? Have you checked NOTAM s for the local area? Does the area for the job include Temporary Flight Restrictions (TFR) or Prohibited A reas ? ** NO flights are permitted within the boundaries of a TFR or Prohibited Area

. Is the flight within a Special Flight Rules Area? Flying within these requires special procedures. Check FAA.gov for updates on these areas which include Wa shington, D.C., The Hudson River in New York, Luke Air Base and other areas around the United States. Have you checked the weather for trends and for weather that may pose a hazard for the intended flight? Are storms or weather limiting visibility predicted for the time and place of the flight operation? Is the weather equal to or better than company minimums AND above the pilot’s personal minimums ? (Refer to FAR 91.155 for visibility, cloud clearance and visibility required to conduct the flight. C heck winds <15 knots and not gusty

– Your personal minimums can be more conservative than the company’s but not less . You don’t HAVE to fly!) **On the day**  **of the flight**  **, re**  **- check the questions**  **above and a**  **nswer the follow**  **ing questions :** Aerial Logistics NW LLC

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35 

### Has a site assessment been conducted that allows you to examine the area of operations surrounding the job site for hazards within the area where the drone will fly? (If “no,” conduct that before proceeding with this form) Has the pilot and visual observer walk ed the flight path l ooking for hazards ? Did the pilot check the appropriate VFR and if applicable the IFR Aviation Charts for the site to see if airports, air traffic , instrument approach procedure routes, towers, wires or obstructions are charted which may affect the conduct and safety of the flight? (Note these hazards on the mitigation plan). Did you check local road maps for the presence of noise sensitive areas (such as schools, hospitals, eldercare facilities, churches conducting services ) or other sensitive areas , (cemeteries, historical sites or wildlife refuges)? ( If “yes” include these on the mitigation plan ?) Are there people ( including spectators , gatherings of people ) in the open within or outside of the edges of the proposed flight path? If “yes,” note them on your mitigation plan and prepare a plan to reduce the risk our operation might pose to them. V erbally notify people in the area that you will be conducting drone operations. Stay clear and do not overfly uncovered people, pets, livestock, vessels and vehicles

. Avoid overflying property that could be damaged if struck by a falling drone. Did you post warning signs , company observers or otherwise bloc k access to the job site where our drone will be operating? Has the pilot pl anned and delineated a “safety zone” to keep the flight path clear of people, property and obstructions?Aerial Logistics NW LLC

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36 

### Does the pilot have emergency landing area s along the route that can be rapidly reached to safely land the drone f rom any point in the flight in the e vent of an unchecked hazard, mechanical failure, unexpected weather or other hazard? Is the take
- off and landing area clear of people and obstructions and segregated from public access? Wi ll the pilot and observer have clear and unobstructed sight of the drone throughout the planned flight? Can the pilot avoid other aircraft and can the observer(s) restrict or warn persons, vessels or vehicle s that may enter the flight path? Is the pil ot satisfied that the drone is in 100% safe and serviceable condition? I f “no,” do not fly until repair and (if required) a functional test flight is successfully flown. Wi ll the pilot and observer have clear, unobstructed verbal communication with each other at all points of the flight? Can you describe how you will maintain altitude below a maximum of 400 feet above the ground? Can you complete all operations during daylight hours? ( Flights must not begin before sunrise nor continue after sunset )

. A re there any other drones working in your area? (No more than one drone will normally be permitted at any one time within the same block of designated airspace). D id you turn off all personal electronic devices? NOTE: Except for devices used to call between the pilot and observer , cell phones, radios, devices which use earbuds, head phones or other similar distracting devices should be turned off during flight operations

.Aerial Logistics NW LLC

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37 

### Are there high voltage electric lines, radar dishes or other high power electrical facilities in the area which may interfere with the radio control devices transmitting between the drone and the pilot? **POST FLIGHT PROCEDURES:** Record flight time on the risk management assessment sheet and in the drone’s logbook. In keeping with 14 CFR, section 61.51 t he pilot shall maintain a record of each flight (in a personal logbook or other acceptable record)

. Do a post
-flight inspection on the remote controls and aircraft for wear or damage. Complete the Safety Mitigation Plan and t urn all paperwork associated with the flight into company management.Aerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

38 

### D **escribe the characteristics of the area of intended operation(s) and the associated potential hazards, in accordance with the statutory**  **mandate under Section 333 regarding proximity**  **to populated areas.** Aerial Logistics NW LLC intends to conduct business operations within the 50 United States. Whether working in a sm all local area or in diverse places, it is the pilot’ s responsibility to assess and mitigate risks. The com pany provides the pilot with a checklist/questionnaire to help with the site survey and risk assessm ent. After using these safety/operational planning tools the pilot develops a written risk mitigation plan to both docum ent and ensure the pilot and later, the com pany that all available risks had been taken into consideration before a flight was conducted. After the flight, the pilot evaluates the effectiveness of the mitigation plan. “Lessons learned” ar e passed throughout the com pany to help other pilots and com pany em ployees to learn from

the valuable lessons, and reduce similar risks at future jobs. These risk assessm ent and mitigation tools are submitted to the com pany m anagem ent and kept as a matter of record. They are to be used in future operations to plan safe and efficient ways to do the next job. These tools are living docum ents, i.e. the com pany will continue to m odify and update them

. “ Lesson s learned ” will be com piled and passed to pilots a nd observers and used to train new em ployees and crews. 

### Describe if **yo u**  **intend to operate in the proximity of any airports, in accordance**  **with the statutory**

**mandate under Section 333 regarding proximity to airports.**  Aerial Logistics NW LLC 

### will follow the regulatory guidance for UAS of remaining clear of airports by at least 5 miles and airspace other than Class G. For a ny exceptions to this the company will request a Certificate of Authorization (COA) from the local FAA Flight Standards Di

strict Office (FSDO). Any operation in the proximity of airports will be outlined and discussed with the airport management and the control tower (if applicable) with details including distance, height, time of operation , duration and the pilot and company’ s point of contact information

. The pilot will remain in contact by telephone with the tower during any operation near an airport that is approved by the FAA. 

### Describe any

**procedures as**  **they**

**w ould**  **be implement**  **ed for conducting a**  **preflight safety**

**risk assessment to determine that the UA S is in a condition for**  **safe flight (14 CFR § 91.7(b))**Aerial Logistics NW LLC

kauaichoppers@yahoo.com 12 February 2016

39 **Sec. 91.7**
**— Civil aircraft airworthiness.**  (b) The pilot in command of a civil aircraft is responsible for determining whethe r that aircraft is in condition for safe flight. The pilot in command shal l discontinue the flight when un ai rworthy mechanical, electrical, or structural conditions occur. As noted earlier, t

he manufacturer of the com pany’s sUA provide guidance in m aintaining them in the operator’

s manual provided when purchasing the sUA. In the interest of safety of flight, efficient operation and preservation of com pany assets the com

pany sUA will be maintai ned to manufacturer’

s standards. The manufacturer provides a troubleshooting guide, a 24/7 hotline for assistance in maintaining the sUA, and deep
-level repair at their US facility. Any com pany sUA t

hat has undergone maintenance or alterations that affec t s the operation or flight characteristics will undergo a functional test flight prior to conducting further op erations under this exemption. Functional test flights will be conducted by a pilot with a visual observer and shall rem ain at least 500 feet fro m other people in such a manner so as to not pose an undue hazard to persons and property. **End of document**