October 5, 2015 

United States Department of Transportation 

Federal Aviation Administration 

Docket Management System 

1200 New Jersey Avenue, NE 

Washington, DC 20590 

Filed in www.regulations.gov 

Akin Gump 

STRAUSS HAUER & FELD LLP 

GREGORY S. WALDEN 

+1 202.887.4213/fax: +1 202.887.4288 

gswalden@akingump.com 

Re: Petition for Exemption of Linking the World under Section 333 of the FAA 

Modernization and Reform Act, 49 U.S.C. 44701(f), and 14 C.F.R. Part 11 

As counsel for and on behalf of Linking the World, we hereby seek an exemption from certain 

Federal Aviation Regulations enumerated below, as authorized by Section 333 of the FAA 

Modernization and Reform Act ("Section 333"), Subsection 44701(f) of the Federal Aviation 

Act, and pursuant to the procedures set forth in Part 11 of the Federal Aviation Regulations, to 

allow Linking the World to operate the following unmanned aerial vehicles ("UAVs") to assist 

first responders in disaster response settings and in search and rescue operations: the senseFly 

eBee, the senseFly eXom, the Parrott BeBop, the 3D Robotics Aero-M, the 3D Robotics Iris+, 

the 30 Robotics X8-M, and the 3D Robotics Solo. 

Linking the World will comply with the standard conditions and limitations included in 

numerous Section 333 exemptions granted recently. Accordingly, we respectfully ask the FAA 

to grant this petition in summary fashion, and obviate Federal Register publication and public 

comment. 

Linking the World through Aid, Empowerment and Advocacy is an international NonGovernmental Organization ("NGO") that focuses on breaking the cycles of poverty through its 

programs to empower communities, its crisis response efforts, and the innovative way it 

leverages technology and new models of cross-sector collaboration. 

Linking the World created the Help and Locate Operations ("HALO") program that utilizes 

UA Vs and remote sensing platforms to provide NGOs and first responders with critical highvalue data for immediate situational awareness and significantly improved responsiveness in 

disaster response settings. The HALO team typically arrives prior to first responders, gathering 

high-value imagery, in real-time, to coordinate relief efforts, hazard analysis, and infrastructure 

weaknesses. Traditional aerial Search and Rescue ("SAR") operations in traditional fixed-wing 

Robert S. Strauss Building 1333 New Hampshire Avenue, N.W. Washington, D.C. 20036-1564 I 202.887.4000 I fax 202.887.4288 1 akingurnp com 
Linking the Word Petition for Exemption 

October 5, 2015 

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aircraft and helicopters is cost prohibitive, while ground teams require significant ground 

resources and are limited in their coverage. The small, highly maneuverable UAVs with highresolution cameras allow us to conduct SAR activities for a fraction of the cost, risk and 

resources, both domestically and internationally. 

The name of the applicant is Linking the World, 211 North Ervay, 4th floor, Dallas, Texas 

75201. The primary contact is Mina Chang, Chief Executive Officer. Her telephone is 972 522 

9189. Her email is mina.chang@linkingtheworld.org and Linking the World's web address is 

www.linkingtheworld.org. 

Exemptions requested 

14 C.F .R. Part 21 ( airworthiness certification) 

14 C.F.R. Part 27 (normal category rotorcraft) 

14 C.F.R. 61.113 (a) and (b) (pilot certification and qualification) 

14 C.F.R. 91.7(a) (airworthiness) 

14 C.F.R. 91.119(b) and (c) (minimum safe altitudes) 

14 C.F.R. 91.151(a) and (b) (fuel requirements in VFR conditions) 

14 C.F.R. 91.405 (a) and (b) (maintenance) 

14 C.F.R. 91.407(a)(l) (approval for return to service) 

14 C.F.R. 91.409( a) ( annual and airworthiness certification inspection) 

14 C.F.R. 91.417(a) and (b) (maintenance records) 

Safety equivalence or no adverse effect on safety 

Unmanned Aerial Vehicles and Systems 

Each of the UAVs Linking the World seeks authority to operate has been approved for 

commercial use in many section 333 exemptions to date. Given their small size, operational 

capabilities, and the restricted areas in which the UAVs will operate, an exemption from Part 21 , 

Subpart H, Airworthiness Certificates, and 14 C.F.R. 91.7(a), is warranted: these UAVs satisfy 

the equivalent level of safety as compared with manned aircraft and meet the criteria in section 

333. 

Each UA V (with payload) is less than 55 pounds, carry no explosive materials or flammable 

liquid fuels, and would operate outside controlled airspace, with no passengers or crew on board. 

As the FAA has found in granting an exemption to Clayco, Exemption No. 11109, at page 10: 

The limited weight significantly reduces the potential for harm to participating and 

nonparticipating individuals or property in the event of an incident or accident. The risk 

to an onboard pilot and crew during an incident or accident is eliminated with the use of a 

UAS for the aerial operations. 
Linking the Word Petition for Exemption 

October 5, 2015 

Page 3 of7 

For the reasons outlined above, Linking the World also seeks an exemption from the certification 

requirements for normal category rotorcraft in Part 27. 

In support of Linking the World's request for an exemption from 14 C.F .R. 91.405( a), 

91.407(a)(l), 91.409(a)(l) and (2), and 91.417(a) and (b), Linking the World will adhere to the 

following inspection and maintenance program: it will inspect the UAS before and after each 

operation, as well as perform weekly, monthly, and annual inspections. Before each flight, the 

pilot in command will inspect the UAS to ensure it is in a safe condition for flight. The preflight 

inspection will account for any discrepancy, such as an inoperable component, item, or 

equipment. Linking the World will not initiate a flight if the inspection reveals a condition that 

adversely affects the safety of operations, and will not operate that UAS until it is found to be in 

a safe condition. Any UAS that has undergone maintenance or an alteration that affects the 

UAS's operation or flight characteristics will undergo a functional flight test before return to 

service. 

Linking the World will follow the manufacturer's UAS requirements relating to components, 

maintenance, overhaul, replacement, inspection and life limits. It will record all maintenance, 

alterations, and the functional flight test in the UAS logbook, including total flight hours, 

description of work accomplished, and the signature of the UAS technician who returned the 

UAS to service. 1 

Linking the World's UASs are equipped with an altimeter that provides the pilot with real-time 

telemetry data in addition to a constant digital display of altitude, speed, and UAS proximity. 

Moreover, the UASs will be operated within the visual line of sight of the pilot in command and 

observer and below 400 feet AGL. In addition, the flight controllers are programmed not to 

allow the aircraft to exceed the 400 feet ceiling, even if the pilot command input is in-conflict, or 

if communication with the remote control transmitter fails. Accordingly, we do not believe an 

exemption from 14 C.F.R. 91.121 is required. 

In support of Linking the World's request for an exemption from fuel requirements in 14 C.F.R. 

91.15l(a) and (b), we note that each UAS is battery-powered and is operated for brief periods of 

time, within the battery capacity of the UAS. 

UA V and UAS Operator Qualifications and Training 

In support of its request for an exemption from the pilot certification and qualifications 

requirements in 14 C.F.R. 61. l 13(a) and (a), Linking the World asserts that an equivalent level 

of safety is achieved by the DAS-specific experience of its pilots. Each pilot, before conducting 

a commercial operation under the requested exemption, will have performed at least 20 takeoffs 

and landings of the particular UAV, and flown the particular UAV for at least 5 hours. In 

1 We believe the FAA has in its possession the manufacturer manuals for each UAS sought to be operated under the 

requested exemption. We will provide any manufacturer manual upon request. 
Linking the Word Petition for Exemption 

October 5, 2015 

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addition, each pilot will hold a valid and current private pilot, recreational pilot, or sport pilot 

certificate. 

UA V and UAS Operating Parameters 

Linking the World will operate its UASs in full compliance with the applicable manufacturer 

manual. 

All flights will be conducted within the visual line of sight of the pilot in command, within noncontrolled airspace. Although the UAS may be operated in a metropolitan area, it will be 

controlled and monitored only by authorized personnel, and be flown below 400 feet AGL. 

Linking the World will also notify the appropriate Flight Standards District Office "("FSDO") 

and/or Air Traffic Control for any operation within five miles of an airport. 

Linking the World will conduct a briefing before each day's operations, which all personnel 

participating in the operations must attend. It will obtain written consent of any person who will 

be participating in the operations or otherwise be on the private property where operations are to 

take place. It will limit its operations to daytime Visual Flight Rules ("VFR"). 

Linking the World seeks an exemption from the requirement in 14 C.F .R. 91.119, subsection (b ), 

that an aircraft must remain at least 1,000 feet above any congested area or open air assembly of 

persons, and subsection (c), that an aircraft must remain at least 500 feet above any person or 

structure in an area other than populated or congested, and not closer than 500 feet to any person, 

vehicle, or structure. These requirements were adopted with fixed-wing, manned aircraft 

operations in mind. While Linking the World may operate its UASs in a metropolitan area, the 

operations will be carefully pre-planned to minimize risk to persons or property, avoid intrusion 

into unauthorized airspace, and avoid a public annoyance. Its UASs will not be operated over a 

highly-congested area or open air assembly of persons. 

Linking the World will make every reasonable effort to ensure that no unauthorized person will 

be on the land over which the UASs will be operated, and will provide notice to adjacent 

buildings and furnish proctors as may be necessary to ensure that unauthorized persons do not 

come within the narrow parameters in which the UASs will be operated. Combined with the 

technological capabilities of the UASs and that the UASs will be operated within the visual line 

of sight of the pilot and an observer, Linking the World submits that its operational limitations 

provides an equivalent level of safety to that provided in section 91.119. 

Public interest 

The proposed operations to assist in disaster response and search and rescue operations serve the 

highest public interest in saving lives, relieving hardships, and protecting real and personal 

property during natural as well as man-made disasters. 
Linking the Word Petition for Exemption 

October 5, 2015 

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Operating UASs under the limitations proposed by Linking the World will avoid any risk of 

harm to pilots as well as persons and people on the ground that would be present during the 

operation of manned helicopters. UAS operations will also require a much smaller energy 

footprint than with manned helicopters. 

Operations limited to the United States 

Under the requested exemption, Linking the World will operate its UASs within the United 

States. 

Summary for Federal Register 

Because petitioner seeks the same authority under the same conditions and limitations as the 

FAA has granted to many petitioners, we believe granting this petition would not set any 

precedent and thus should be subject to summary handling, thereby obviating publication of a 

summary in the Federal Register and public comment.