# C C I

An Audio Visual Company

Communications Concepts, Inc.

7980 North Atlantic Ave. Cape Canaveral, FL 32920 Office 321

- 783

- 5232 FAX (321) 799 1016 

### August 30 , 2015

U.S. Department of Transportation Docket Operations, M

- 30 1200 New Jersey Avenue, SE Room W12

- 140, West Building Ground Floor Washington, DC 20590

- 0001

Dear Sir or Madam:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the "Reform Act") and 14 C.F.R. Part 11, Communica tions Concepts, Inc. (CCI) hereby applies for an exemption from the Federal Aviation Regulations identified herein to allow for t he commercial operation of an Unmanned Aircraft System (UAS) for the purposes of providing high quality aerial imaging and data services for a variety of commercial, public, and residential uses , so long as such operations are conducted within and under the conditions outlined herein or as may be established by the Federal Aviation Administration ("FAA").

CCI has provided expert communications, video, and photographic services since 1978 and wish to add efficient and low

- cost aerial services to our company’s ability to continue providing high

value services to our clients. The advancement of small, light weight, high resolution vi deo and photographic cameras and equipment provides the opportunity to use ultralight and unmanned UAS to quickly provide these services at a much lower cost than traditional manned helicopters and aircraft.

The use of UASs to perform these tasks dramatic ally reduces costs and increases worker and public safety, lowers inspection costs, increases maintenance reliability of facilities and infrastructure and can provide better, faster, more thorough film making and inspections than through the use of manned aircraft. These facts, among others, provide a significant and definitive public benefit and are in the public interest.

A grant of our exemption request, by the FAA, would permit us to conduct flight operations in strict compliance and safety protocols a s mandated and required by regulations and best practices in order to offer our services to private and government entities.

Conditions for UAS operation as described in this application are consistent with and based upon proposed FAA UAS regulations as o utlined by the FAA on the 15th of February, 2015. Any additional conditions included herein have been included by Communications Concepts, Inc. to add to and enhance the safe operation of UASs when used for aerial videography and utility /infrastructure ins pection and management.

CCI contends that this application satisfies the conditions and criteria set forth in Section 333 of the Reform Act, that the operations described herein benefit the public interest as a whole in many ways and that the use of UASs for power line and utility inspection meets or exceeds the level of safety currently experienced by traditional manned aircraft utilized for these purposes. The applicant is thankful for the Federal Aviation Administration's time and consideration.

Respec tfully yours,

James C. Lewis, Jr. President

# Communications Concepts, Inc.

Page 1 

## I. Regulations for which Exemption is Requested

Communications Concepts, Inc. requests exemption from the following regulations:

• Part 21, Subpart H.

• 45.23 (b)

• 45.25

• 45.27 (a)

• 45.29

• 61.113 (a) & (b)

• 61.133 (a)

• 91.7(a)

• 91.9 (b)(2) &(c)

• 91.103

• 91.105

• 91.109(a)

• 91.119

• 91.121

• 91.151 (a)(1) & (b)

• 91.203 (a) & (b)

• 91.405 (a)

• 91.407(a)(1)

• 91.409(a)(2)

• 91.417 (a) & (b)

A discussion of each FAR and the methods by with Communications Concepts, Inc. will maintain a level of safety equivalent to or exceeding the rules from which exemption is sought is detailed in Section VI of this petition.



## II. Statutory Authority for Requested Exemptions

This petition for exemption is submitted in accordance with Section 333 of the Reform Act. Congress has
directed the FAA "t o safely accelerate the integration of civil unmanned aircraft systems into the national airspace system." Pursuant to Section 333 of the Reform Act, the FAA Administrator is to permit operation of an unmanned aircraft system where it does not create a haz ard to users of the national airspace system ("NAS") or the public or pose a threat to national security based on the following considerations:

• The size, weight, speed and operational capability;

• Operation in proximity to airports and populated areas; and

• Operation within visual line of sight of the operator.

Furthermore, the Federal Aviation Act grants the FAA Administrator general authority to grant exemptions from the agency's safety regulations and minimum standards wh 1` en the Administrator decides a requested

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Page 2 exemption is in the public interest. See 49 U.S.C. §§ 106(f), 44701

- 44716, et seq. A party requesting an exemption must explain the reasons why the exemption: (l) would benefit the public as a whole, and (2) would n ot adversely affect safety or how it would provide a level of safety at least equal to the existing rules. See 14 C.F.R. § 11.81.



## III. Communications Concepts, Inc. Background Information

Communications Concepts, Inc. (hereafter referred to as “CCI”) is a n audio visual production company specializing in video and digit al media production, training systems and documentation

. Founded in 1978,
CCI is an established Type C Florida Corporation and recognized leader in imaging in Central Florida. The founder, James Lewis, has logged hundreds of hours in aerial film and video production. This commercial work has included everything from aerial documentation of most of the property in Hobe Sound, Florida for conversion land use to aerial production for music videos in Jacksonville, Florida to aerial survey of sand deposits for Port Canaveral. In the last few ye ars, CCI has shot aerials with traditional helicopter s for two major motion pictures ( Transformers 3 and Space Brothers ) a nd for a number of tourism destination videos. CCI has a perfect track record and is known for providing safe, efficient , reliable and high quality aerial imaging services to its diverse groups of clients.

Communications Concepts, Inc

. believes utilizing Unmanned Aerial Systems ( U AS s) rather than manned aircraft will improve safety , efficiency and effectiveness for many of these applications. Because of CCI’s "real world" knowledge of planning and capturing aerial images and documentation, Communications Concepts, Inc. is well versed and prepared for safe and efficient operation of their own UAS s should this petition be granted.



## IV. Proposed Operations

Communications Concepts, Inc. is requesting exemptions from the Federal Aviation Regulati ons (the "FARs") stated herein pursuant to Section 333 of the Reform Act in order to perform Aerial video, photography, live feed, and other sensor operations utilizing UAS s to provide high quality aerial imaging and data for a variety of commercial, publi c, and residential uses, specifically targeting:

• Aerial video/photography for motion picture and commercial filming/imaging/video recording

• Aerial video/photography to support the recording real estate listings for marketing properties

• Aerial video/photogr aphy or providing environmental and system monitoring and inspection

• Aerial mapping (photogrammetry) and video documentation, such as new and existing construction, transportation and utilities, land development, environmental mitigation projects,

etc.

• Aerial video/photography or providing live video feed to support tower inspections and maintenance support such as aerial viewing, video recording, signal analysis, laser measurements,

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Page 3 etc.

• Aerial video/photography or providing live video feed for assessme nt of other tall structures such as wind turbines, smoke stacks, water towers, flare stacks, etc.

• Aerial video/photography or providing live video feed to assist with search and rescue operations in cases of an emergency or natural disasters

• Aerial data an d video transmission relay for coverage and timing of broadcast, sporting and special events, such as relaying video from in

- car cameras at motorsports events or remote cameras at marathons or golf events,



### A. Operation Locations and Environments

Communications Concepts, Inc. will operate its UASs in support of aerial imaging and data collection

.
Aerial video/photography for motion picture and commercial filming/imaging/video recording. To date CCI has performed this type of imaging work utilizin g helicopters and fixed wing aircraft. Such craft are often required to operate for extended periods flying redundant routes and holding positions for long periods of time. This places the helicopter, its occupants, and possibly the public, in potential harms way.

Use of a UAS would eliminate these concerns. The lack of occupants eliminates potential harm to the pilot, imaging crew and onboard observers. The small size of the UAS reduces or eliminates much of the risk to the public, especially when you c onsider a UAS also does not carry flammable fuel and does not release emissions.

The UASs will be controlled via radio transmission from a Ground Control Station ("GCS"), augmented by the UASs’ internal GPS, altimeter and gyros. All remote control equipme nt will be off the shelf industry standard devices available to both professionals and consumers and utilize FCC approved transmission and reception components. Much like when helicopters and aircraft have been used, a UAS flight will be planned and flow n to comply with FAA regulations
, including use of the FAA B4UFLY app when it becomes available. The UASs used will not violate airspace restrictions for airports or airbases, government facilities, National Parks, sensitive structures, and so forth. All UAS flight operations will be under 400 feet. This planning wil l assure Communications Concepts, Inc.'s UASs are operated in a safe and secure manner . At no time will the UAS s be operated over any non

- participating persons or properties

. The flight area will b e monitored by the operator with live video streaming from each UAS for any changes in environment or encroaching individuals.

Communications Concepts, Inc. will confer with the clients and property owners and their representatives regarding any known hazards or abnormal operating conditions that are pertinent to UAS operations. Permission from all parties involved will be obtained prior to conducting commercial flight operations
within flight path, imaging area and vicin ity

. Communications Concepts, Inc. will utilize a n operator specifically trained in UAS operati ons for all commercial flights. When deemed necessary by Communications Concepts, Inc. observer(s) will be

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Page 4 utilized for added visual coverage. They may also utilize a live video feed from the UAS to monitor the flight area

.
Any observer will be in voice co ntact with the operator at all times during flight via either direct contact, radio or equivalent methods, depending on the optimal observer position as determined by operator and observer. The observer, when used, will assist the operator in identifying b oth air and ground hazards and maintaining safe operating conditions. The flight will be altered or terminated immediately should a hazard such as a low flying aircraft or unauthorized person in the flight area be observed by either the operator or observe r.

UASs will be flown within a half mile line of sight radius of the operator. This reduces flight risks to very manageable levels. The flight area can be secured, any intruders readily spotted and flights quickly and safely terminated to multiple landing zones , if need be. Additionally, the UAS will not be operated over

non

- participating persons. It will remain a safe distance of all structures an d will not operate higher than
4 00 feet AGL.

Predetermined potential landing zones will be identified and brie fed by the operator, observers and participating persons prior to flight. Landing zones will be selected according to proximity to obstructions, observed ground conditions and limited exposure to persons and property. Primary landing zone and launch zone will be one in the same and defined as “home”

. UASs will be programmed to return ho me automatically in case of loss of signal or other anomaly.

Aerial video/photography to support the recording real estate listings for marketing properties

. Technically, this work is much like the imaging work CCI performs for the motion picture and commercial filming. In the case of video and photography of property and other real estate, flight plans will be performed for and coordinated with the property owner their ag ents. Adjacent property owners will be notified of the UASs filming plan prior to flight. Most flights will be relatively low level and well with beneath the 400 foot ceiling for UAS flig ht. Most requirements for real estate videos are generated by real estate transactions and sales. Often times the cost of using traditional helicopters or other manned aircraft prohibitive when compared to the value of the real estate and the commissions paid on sales. The reduced cost of using UAS systems will allow g reater use of aerial imaging that will provide for better educated buyers and benefit the economy and the tax base through increased real estate transactions.

Aerial video/photography or providing environmental and system monitoring and inspection

. CCI h as already demonstrated the value quality aerial images and inspections provide based on the aerial work we have performed for land owners to document land usage, conditions and changes and for government agencies to plan for natural topography and oceanog raphic changes and to mitigate man

- made impacts and conditions. Often times, this aerial work requires flying repetitive route such as track and crawl, parallel track and parallel sweep patterns or re

- flying the same pattern over again on a regular repeat ed monthly or annual basis. This type of flying is often at low altitude which increases risks to pilot, crew and observers and the sound can be disturbing to people and wildlife. CCI would eliminate these risks and annoyances with a small, safe and quie t UAS alternative which at the same time will provide highly improve data quality and reliability since the UAS flies on GPS based tracks and patterns which will assure accuracy and repeatability at a much lower cost.

Aerial Mapping (Photogrammetry) and Video Documentation of large projects, natural disasters, and

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Page 5 large scale emergencies

. Low

- level photography is far more effective than ground based imagery for displaying the characteristics of large, complex properties with ongoing construction, or transportation and/or utility corridors. Communications Concepts, Inc. as a routine part of its business have contracted both Helicopter and Fixed wing aircraft for this type of work. However, espe cially in the case of small projects or projects, manned aircraft prove too costly or unable to acquire data at low enough speeds or altitude to meet these requirements. The benefits of reduced cost and improved quality from the UA S will be valuable to and benefit many users of this aerial data.

Inspections and Maintenance Support of Towers and Other Tall Structures. UAS flights to achieve an aerial view, video recording, signal analysis, laser measurement of wireless provider antennas and lines that

are se cured to cell phone towers presents a high potential for dramatically lowering costs and increasing safety related to providing this service. Through mounted equipment on the UAS, we will be able to observe, analyze, and acquire valuable data without the r isk of using a tower climber. This elimination of unnecessary climbs required for visual inspections, measurements, and signal analysis would result in less danger in making for safer working environment by reducing the frequency need to climb the towers. Typical servicing requires technicians to make multiple climbs up the tower before attempting any repair
work.

Data captured from these flights will assist in determining not only the physical condition of the tower’s equipment, provide real

- time functiona lity and transmission ability of the tower, and view/record open antenna locations on towers for potential future modifications and additions. Information gathered can provide indication of malfunction, damage from lightning strikes, strobe light condition s, cable condition. The UAS will also be used to measure signal strength and mapping of the tower’s equipment to determine proper functionality and/or interference created by faulty equipment.

Additionally, these towers and facilities are highly restricted areas with low potential for public bystanders to be in the area. The height of these structures also require the airspace in the immediate vicinity to be highly restricted from any and all air traffic and therefore offer a minimal likelihood of interferi ng with aircraft operations

.
Aerial data and video transmission relay for coverage and timing of broadcast, sporting and special

events. Many video and data transmission systems are very directional and only work in

- line of sight. For some events, such as television coverage of a golf event line of sight is not possible due to trees and other structures. Likewise, if the transmission point is moving, such as race car on a track, ground based reception and tracking is not dependably possible over the entire track. Until now, in those instances, CCI has retained a helicopter to be a reception and relay point in the sky that has clear video to both the

transm ission and reception destination. This requires the helicopter to hover in the same position for duration of the event. Again, UASs is well suited for this application as it can hold its position based on its internal GPS and altimeter. Such a solution great lowers cost and highly reduces risks to all parties involved.



### B. Operating Conditions and Limitations

All operations will be conducted according to and in compliance with the following conditions and limitations.

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Page 6 (A) All UASs utilized will weigh less tha n 55 lbs. (25 kg) (B) The aircraft will remain within visual line

- of

- sight ("VLOS") of the operator and / or visual observer(s) at all times using vision unaided by any device with the exception of corrective lenses (C) A visual observer ("VO") may be utilized to satisfy the VLOS and observation requirements as defined herein (D) The aircraft will not operate over non

- participating persons (E) Flight operations will typically be conducted only between the period of official sunrise and sunset as defined in the Aeronautical Information Manual (AIM) . Should a night operation be required, CCI will provid e the FAA with a safety case that contains sufficient mitigation to avoid collision hazards at night. This request will be provided well in advance of any night operation. Nig ht operations will be conducted only if the FAA approves the request. (F) The UAS will yield right

- of

- way to other aircraft, manned or unmanned. If there is a risk of a collision, the operator will immediately maneuver away. (G) Prior to flight, the UAS operator w ill assess weather conditions using FAA approved weather sources and direct weather observation, will check airspace restrictions and TFRs and will assess the location of people and property to lessen risks if he or she loses control of the UAS

. (H) Flight ope rations will be conducted only with flight visibilities at or exceeding 3 statute miles. (I) The UAS will not be operated in airport flight paths, restricted airspace, or areas under current Temporary Flight Restrictions (TFRs). (J) The operator will discontinue the flight when continuing would pose a hazard to other aircraft, people or property. (K) The UAS will not exceed an airspeed of 87 knots (100 mph). (L) The UAS will not be operated at an altitude exceeding 400 feet above ground level ("AGL"). (M) Operations will not be conducted in Class A airspace. (N) ATC permission will be obtained prior to operations in Class B, Class C, Class D or Class E airspace. (O) The operator / observer(s) will operate / observe only one UAS at a time. (P) A thorough preflight of the UAS will be conducted by the designated operator in command ("OIC") prior to the first flight of the day or after any suspected or observed anomalies or damage. (Q) The OIC will follow the suggested preflight actions as outlined in the UAS operator's man ual or, if available, Communications Concepts, Inc.'s UAS operation guidelines. (R) The operator will not operate an UAS should he or she know or has any reason to know of any physical or mental condition that would interfere with their safe operation of the aircraft. (S) The UAS will not be operated in a careless or reckless manner.



### C. Operator Certification and Requirements

All Communications Concepts, Inc. operators will abide by the following conditions and requirements.

(A) The OIC must have accumulated and logged, in a manner consistent with 14 CFR § 61.51 (b),

a minimum 10 hours of total time as a UAS pilot and at least 5 hours logged as a UAS pilot

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Page 7 with a similar UAS type (B) All operators will be 18 years of age or older. (C) Operators
, or a designated Communicat ions Concepts, Inc. official will make available to the FAA, upon request, the UAS for inspection or testing. (D) Operators or a designated Communications Concepts, Inc. official will maintain a log of flights as practicable for future currency or flight loggi ng requirements. (E) An operator or a designated Communications Concepts, Inc. official wil l report an accident to the FAA within 10 days of any operation that results in damage to property, other than the aircraft, estimated to exceed $25,000 for repair (incl uding materials and labor) or fair market value in the event of total loss, whichever is less and / or results in significant injury or death.



### D. UAS Registration, Markings and Requirements

Applicable Codes of Federal Regulation require aircraft to be mar ked according to certain specifications. Communications Concepts’ UAS, by definition, is unmanned. Therefore the UAS does not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, two

- inch lettering is difficult to plac e on such small aircraft with dimensions smaller that minimal lettering requirement. The FAA has previously issued exemptions to this regulation through Exemptions Nos. 8738, 10167, 10167A and 10700.C. 14 C.F.R. 91.119: Minimum Safe Altitudes.



## V. Public Benefit and Public Interest

Currently, the services listed in Section IV. Proposed Operations are performed vi a helicopter or fixed

winged aircraft. The aircraft are typically flown at low altitude and in relative close proximity to the facilities and structures or components being imaged. The use of a UAS rather than a manned aircraft in such applications will further the public interest in several areas including but not limited to the following:

• The UAS carries no passengers, pilot or crew, thereby i ncreasing pilot, passenger and worker safety

• The UAS ca n often eliminate the need for worker s to climb a tower s, pole s or other structures in order to inspect components thereby increasing worker safety.

• The UAS carries no flammable fuel thereby increasing safety to the general public.

• The UAS has a lower noise signature than a typical helicopter or aircraft thereby improving public welfare.

• The UAS has no emissions thereby reducing the environment impact over traditional manned
aircraft.

• The UAS is less ex pensive to operate than a traditional manned aircraft thereby decreasing the cost of obtaining these services

.

• The UAS is less expensive to acquire than a manned aircraft thereby allowing for more inspection crews to operate concurrently. This can result i n bette r

- maintained infrastructure, more reliable

power or celluar distribution for the public and better knowledge base to make educated decisions

.

• The UAS may respond to natural disasters and storm

- related damage quicker than manned

aircraft. This result s in faster response an d restoration of utility service such as power restoration

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Page 8 and lower outage time for the public.



## VI. Discussion of Requested FAR Exemptions

Communications Concepts, Inc. seeks an exemption from the following regulations including pro visions of Part 21, 45, 61 and 91 for the purposes of conduction the operations described herein. Presented here are the specific FAR sections for which exemption is requested and the methods and safeguards by which Communications Concepts, Inc. will ensur e a level of safety equivalent to exceeding the regulations from which exemption is sought. See 14 C.F.R. § 11.81(e).

A. 14 C.F.R. Part 21, Subpart H

— Airworthiness certificates

Section 91.203(a)(1) requires civil civil aircraft to have "an appropriate and current airworthiness certificate." Part 21, Subpart H ("Airworthiness Certificates") establishes the procedural requirements and applicability for the issuance of airworthiness certificates as directed by 14 C.F.R. § 91.203(a)(1).

Equivalent level of safety: The UAS s operated will be have a gross weight less than 55 lbs. and will be flown at speeds less than 87 knots (100 mph). They do not carry a pilot or passengers, do not carry flammable fuels and will be operated in well

- defined locations using an operator and, i f deemed required by Communications Concepts, Inc., a visual observer(s). All operations will be conducted in compliance with the limitations and conditions stated in this petition for exemption. The Federal Aviation Act and Section 333 of the Reform Act b oth authorize the FAA to exempt aircraft from the requirement of an airworthiness certificate upon consideration of the UAS ' size, weight, speed, operational capability and proximity to airports and populated areas.

The UASs will not have an airworthiness certificate, and there is no FAA regulatory standard for determining airworthiness of the UASs. Additionally, Communications Concepts’ operating documents set forth inspection and maintenance procedures to ensure airworthiness. The characteristics and condi tions under which the UAS s will be operated, as outlined in this petition, given the size, weight, speed, operation capability and proximity to airports and populated areas, achieve or exceed the equivalent level of safety over a manned aircraft with an ai rworthiness certificate used for the purposes outlined in this petition.

The FAA has stated that no exemption is required from this section if a finding is made under the Reform Act that an UAS provides an equivalent level of safety when compared to aircraft normally used for the same application. See granted exemptions 11138, 11062, 11067, 11080, 11114 and 11112.

B. 14 C.F.R § 45.23 (b)

- Display of marks; general

Regulation 14 C.F.R. § 45.32 ( b) states: "...the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words limited,' 'restricted,' light

- sport,' 'experimental,' or 'pr ovisional,' as applicable."

Equivalent level of safety: These UAS does not have a "cabin, cockpit or pilot station entrance" therefore the required marks cannot be displayed "near each entrance." Additionally, letters not less than 2 inches nor more than 6 inches may not be practical given the small size of the UAS . If the UAS is too small to display

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Page 9 markings in the size described in regulation § 45.23 (b), then markings will be displayed in the largest practicable manner.

C. 14 C.F.R. § 45.25

— Location of marks on fixed winged aircraft

Regulation 14 C.F.R. 45.25 describes the marking requirements on fixed winged aircraft. It states that the aircraft, "...must display the required marks on either the vertical tail surfaces or the sides of the fuselage...". It continues to describe the specific locations on which marks may be displayed.

Equivalent level of safety: An UAS does not carry a pilot or passengers, does not have a cabin and may have a design that is significantly different than traditional manned a ircraft. As such, the markings requirements of 14 C.F.R. § 45.25 may not be feasible given the design and layout of the aircraft. To provide an equivalent level of safety, the UAS will display required markings on conspicuous locations of the aircraft.

D. 14 C.F.R. § 45.27 (a)

— Location o f marks; nonfixed

- wing aircraft

Regulation 14 C.F.R. 45.27 (a) states: "Each operator of a rotorcraft must display on that rotorcraft horizontally on both surfaces of the cabin, fuselage, boom, or tail the marks required b y §45.23."

Equivalent level of safety: An UAS does not carry a pilot or passengers, does not have a cabin and may have a design that is significantly different than traditional manned aircraft. As such, the markings requirements of 14 C.F.R. § 45.25 may no t be feasible given the design and layout of the aircraft. To provide an equivalent level of safety, the UAS will display required markings on conspicuous locations of the aircraft.

E. 14 C.F.R. § 45.29

- Size of marks

Regulation 14 C.F.R. 45.29 describes the required size of marks and the characteristic of lettering for aircraft. In many cases it dictates that marks must be at least 12 inches high.

Equivalent level of safety: An UAS is, by definition, significantly smaller and may have a design and layout significantly different than traditional manned aircraft. As such, the size and layout of markings as stated in 14 C.F.R. § 45.29 may not be feasible due to the inherent characteristics of UAS s. To provide an equivalent level of safety, the UAS will displ ay required markings on conspicuous locations of the aircraft. If the aircraft is too small to display markings in standard size, then the aircraft will display markings in the largest practicable manner.

F. 14 C.F.R § 61.113 (a) & (b) and 14 C.F.R. § 61.1 33 (a)

- Private pilot privileges and limitations; pilot in command; commercial p ilot privileges and limitations

Regulation 14 C.F.R. § 61.113 restricts private pilots from flying aircraft for compensation or hire and would require a second class medical c ertificate. Regulation 14 C.F.R. § 61.133 requires a pilot to hold a commercial pilot's license when acting as pilot in command of an aircraft used for compensation or hire. This is intended to ensure that the skill and competency of any PIC matches the ai rspace in which the PIC will be operating, as well as requiring certifications if the pilot is carry passengers or cargo for hire.

Equivalent level of safety: Communications Concepts, Inc. UAS s will be operated as part of a commercial

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Page 10 operation, however th ey do not carry passengers or cargo. A dditionally, they remain below 4 00 feet AGL, are operated at less than 87 knots (100 mph), will not be operated over non

- participating individuals, are under 55 lbs. and do not carry flammable fuel. In FAA Docket No. F AA

- 2014

- 0352, the FAA determined that UAS operations did not warrant the additional cost and restrictions imposed by requiring the operator to have a commercial pilot certificate and class II medical certificate.

Additionally, the operators will participat e in UAS specific online training provided by the manufacturer including, basic UAS check out, first flight instruction, advanced flight instruction and other programs as they become available. CCI will also provide a custom designed in

- house program spe cifically tailored to Communications Concepts, Inc.'s operations, UAS s and operating environment. This program will be developed using input and guidance from currently operating UAS training programs and will follow industry standard processes and procedu res. The program will consist of industry standard ground based and hands on training in a controlled flight environment.

Section 333 also requires operations to not pose a threat to national security. The security screening conducted by the Transportation Security Administration ("TSA") of certificated airmen satisfies this requirement and applies to all Communications Concepts, Inc.'s operators.

Using these processes, procedures and restrictions, the level of safety of UAS operations for the uses as outli ned herein is equivalent to or significantly exceed those as regulated by §61.113 and §61.133.

G. 14 C.F.R. § 91.7 (a)

— Civil aircraft airworthiness

The regulations states: "No person may operate a civil aircraft unless it is in airworthy condition."

Equivalent level of safety: The FAA has stated that no exemption is required to the extent that the requirements of Part 21 are waived or found inapplicable. Communications Concepts, Inc. requests that the requirements for § 91.7 be treated in accordance w ith FAR Part 21 Subpart H. Additionally, Communications Concepts, Inc. operators will inspect the aircraft prior to flight in order to ensure it is in a condition that is safe for flight. See granted exemption 11062.

H. 14 C.F.R. § 91.9 (b)(2) & (c)

- Approve d flight manual in the aircraft

Regulation 14 C.F.R. § 91.9 (b)(2) states: "No person may operate a U.S.

- registered civil aircraft ... For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is availa ble in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof."

Regulation 14 C.F.R. § 91.9 (c) states: "No person may operate a U.S.

- registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter."

Equivalent level of safety: Communications Concepts, Inc. requests an exemption from this regulation in part as outlined in the request for exemption from regulation 14 C.F.R. § 91.203 (a) and (b). An equivalent level of safety will be achieved by maintaining the proper documentation at the location of the Ground Control Station readily available to the operator. This includes the UAS operation manual as provided by the manufact urer or equivalent documents as created b y Communications Concepts, Inc.

Additionally, the FAA, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014,

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Page 11 the UAS flight manual, registration certificate and other documentation will be k ept at the control station with the operator during flight. The Chief Counsel's Office has held that for all UAS operations, this alternate method constitutes full compliance with the regulations. See granted exemption 11062.

I. 14 C.F .R. § 91.103

- P reflight action

14 C.F.R. § 91. 103 requires the P IC to become familiar with specific information before each flight, including information contained in the FAA

- approved Flight Manual on board the aircraft.

Equivalent level of safety: The UAS does not have a Flight Manual on board because of its inherent design and lack of on board pilot. The operator will review information prior to flight to maintain the safety of the operation, including but not limited to, the weather, battery levels, landing and takeoff distances and aircraft performance data. The operator will refer to the manufacturer supplied UAS manual for technical data and information as provided. The manual will be kept at the ground station during operations.

The FAA has stated that no exemption is required (see Grant of Exemption No. 11062, p. 20) however, an exemption is requested to the extent that an FAA

- approved Flight Manual is required.

J. 14 C.F.R. § 91.105

- Flight crewmembers at stations

This section contains requirements for crewmem bers during takeoff and landing of the aircraft. The regulation requires crewmembers to be at the crewmember's station unless absence is necessary to perform their duties. It also requires crewmembers to keep safety belt(s), including their shoulder harnes s if so equipped, fastened.

UAS s do not carry pilots or passengers and therefore do not have a "crewmember station." However UAS s do have a Ground Control Station from which an operator controls the aircraft via radio signals. The Ground Control Station may be at a fixed location or may be movable. However, because it is not a physical part of the aircraft, the Ground Control Station may not have a seat(s) and does not utilize safety belts.

Visual observers, when deemed necessary by Communications Concept s, Inc., may be at various locations in the vicinity of the flight operations area in order to provide the best line of sight view of the UAS during flight. The visual observers may or may not be at a fixed location and may or may not utilize a seat. The

s eat will not be equipped with safety belts.

Equivalent level of safety: The UAS operator will remain at the Ground Control Station where the control of the aircraft takes place for the duration of the flight. Visual observers, when deemed necessary by
Comm unications Concepts, Inc., will be positioned in the flight operations area according to the operator's determination of the optimal viewing area given the planned flight. The use of safety belts is not feasible because the crewmember stations are not phys ically a part of the aircraft and are not in motion.

K. 14 C.F.R. § 91.109 (a)

- Flight instruction

14 C.F.R. § 91.109 (a) states that, "No person m a y operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unle ss that aircraft has fully functioning dual controls." UAS s do not have functioning dual controls by design. They are pilote d using a Flight Control System/ Ground Control Station that communicates with the aircraft via radio signals.

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Page 12 Equivalent level of sa fety: During flight instruction, there are no pilots or passengers on the aircraft and the Ground Control Station will be a safe distance from the aircraft. The aircraft will remain a safe distance from non

- participating individuals causing no safety hazar d.

Given the size and speed of the UAS , an equivalent level of safe training can be performed without dual controls because no pilot or passengers are aboard the aircraft and it is a safe distance from the public and

structures.

The FAA has previously appr oved exemptions for flight training without dual controls for a number of aircraft. See Granted Exemptions: 11109, 11138 and 11110.

L. 14 C.F.R. § 91.119

- Minimum safe altitudes

14 C.F.R. § 91.119 prescribes that an aircraft may not be operated closer than 500 feet to any person, vessel, vehicle or structure. The nature of the operations described herein may require operation in relatively close proximity to items such as power line towers or poles. However, operations will not be conducted over non

- participating individuals.

Equivalent level of safety: The UAS s operated by Communications Concepts, Inc. are far smaller than manned aircraft, such as rotorcraft and fixed winged aircraft, used for similar operations. Additionally, the
UAS s do not car ry a pilot or passengers, weigh less than 55 lbs., do not carry flammable fuel, will not exceed 87 knots (100 mph) and will not be operated over non

- participating persons. The UAS s will be operated below 500 feet AGL with the use of an operator and, if det ermined to be required by Communications Concepts, Inc., a visual observer(s) to avoid risk to aircraft, persons and property. This provides an equivalent or greater level of safety than achieved with conventional aircraft currently performing similar oper ations.

M. 14 C.F.R . § 91.121

- Altimeter settings

14 C.F.R. § 91.121 requires an aircraft to be operated by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure when operating below 18,000 feel MSL. Some UAS contain a barometric pressure sensor. Others utilize GPS sensors to determine altitude. Typically barometric pressure sensors are corrected to the point of takeoff; not a departure airport.

Equivalent level of safety: The operator will confirm the ele vation of the launch site prior to launch. This will be compared to the GPS sensor or barometric sensor derived altitude as displayed on the UAS telemetry reading at the Ground Control Station. The operator will then determine the maximum permissible altit ude to maintain flight below 4 00 feet AGL and will not exceed this altitude. The maximum permissible altitude will also be monitored and estimated by visual means through the use of the operator and / or visual observer(s) as a secondary backup to UAS tele metry data. This provides a level a safety equal to or exceeding the regulation.

N. 14 C.F.R. § 91.151 (a)(1) & (b)

- Fuel requiremen ts for flight in VFR conditions

14 C.F.R. § 91.151 (a) (l) states: "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

— (l) During the day, to fly after that for at least 30

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Page 13 minutes..."

14 C.F.R. § 91.151 (b) states: "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."

The UAS will be operated only during daylight hours in VFR conditions. The technical limitations of most
UAS s limit total flight tim e to approximately 4 0 minutes before the battery is depleted. This means that no meaningful flight time would be possible given the limitations of § 91.151 (a) (l) and (b).

Equivalent level of safety: The UAS flight will be terminated with at least 20% res erve power. This allows the UAS to return to its landing zone with adequate power remaining to conduct a safe and controlled landing. Given the UAS’ size, weight and speed, the UAS when operated with this limitation provides an equivalent or greater level of safety than manned aircraft represented by this regulation.

Additionally, flights will be safely landed when the battery falls below its nominal voltage, should that occur prior to completion of the operation. The 3D Robotics Solo UASs that CCI will uti lize offers a Smart Battery System that not only monitors Solo’s remaining battery charge but also helps to account for location, so that the mobile app provides the Pilot in Command (PIC) relevant warnings about when to start to return to home based on th e UASs’ distance from home. The battery communicates with UAS controller, which displays not only remaining flight time but also present power usage. If the PIC continues flying after initial warning, the UAS controller will begin vibrating to further al ert the pilot of the need to land ASAP.

O. 14 C.F.R. § 91.203 (a) & (b)

— Carry civil aircraft certification and registration

The regulation states: (a) "...no person may operate a civil aircraft unless it has ... an appropriate and current airworthine ss certificate." Furthermore: (b) "No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew."

Equivalent level of safety: In regard to 14 C.F.R. § 91.203 Part (a), an equivalent level of safety is achieved through the methods and characteristics as outlined in the request for exemption from 14 C.F.R.
Part 21, Subpart H.

In regard to 14 C.F.R. § 91.203 Part (b), the UAS does not carry a pilot or passengers, does not have a "cabin or cockpit entrance" and does not have onboard storage in which to carry certification and registration documents. An equivalent level of safety will be achieved by maintaining the proper documentation at the Ground Control Station readily available to the operator. The FAA has issued numerous exemptions to this regulation. See granted exemptions 9565A, 9565B, 9789, 9789A, 9797,
979 7A, 9816A and 9816.

Additionally, the FAA, in accordance with FAA Office of Chief Counsel's Opinion dated August 8, 2014, the UAS flight manual, registration certificate and other documentation will be kept at the control station with the operator during f light. The Chief Counsel's Office has held that for all UAS operations, this alternate method constitutes full compliance with the regulations. See granted exemption 11062.

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Page 14 P. 14 C.F.R. §§ 91.405 (a), 91.407 (a)(1), 91.409 (a)(2), 91.417 (a) & (b)

- Maintenance inspections

The regulations 14 C.F.R. §§ 91.405 (a), 91.407 (a)(l), 91.409 (a)(2) and 91.417 (a) & (b) specify maintenance and inspection standards in reference to 14 C.F.R. Part 43. Specifically, 14 C.F.R. § 91.405 (a) requires that each owner o r operator of an aircraft, "...s hall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspection ... have discrepancies repaired as prescribed in part 43 of this chapter." An exemption is required from these regulations because Part 43 and these sections apply only to aircraft with an airworthiness certificate, which the UAS s will not have.

Equivalent level of safety: The UAS s will be maintained and inspected in accordance with the manufacturer

- supplied manual . This includes maintenance, overhaul, replacement and inspection requirements for the UAS s. The operator, prior to the first flight of the day and as deemed necessary otherwise, will undertake preflight inspection procedures in order to ensure the UAS is in a condition for safe operation. Discrepancies that may affect the safety of flight will be addressed and repaired if required. The operator, and Communications Concepts, Inc., will maintain the UAS s in a condition for safe operation. Given the size, cha racteristics and operating limitations of UAS s as described herein, this provides a level of safety equivalent to or greater than manned aircraft performing similar operations.